Finding 1203061 (2025-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396290
Organization: County of San Diego (CA)
Auditor: EIDE BAILLY LLP

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to FFATA submissions for COVID-19 grants.
  • Impacted Requirements: The County failed to document independent reviews of FFATA submissions for all tested subawards, violating 2 CFR Section 200.303(a) and FFATA reporting requirements.
  • Recommended Follow-up: Revise procedures to ensure documentation of independent review and approval of reports before submission to enhance compliance controls.

Finding Text

Program: COVID-19 CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: N/A - Direct Award Award No.: B20UW060501, B24UC060502 Award Year: 2021, 2025 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: As a result of our audit procedures, we noted that for three (3) out of three (3) first tier subawards tested there was no documented review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions. Cause: The County’s procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: We tested the entire population of three subawards obligations during the year. Repeat Finding from Prior Years: No Recommendation: We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

Corrective Action Plan

Reference Number 2025-002: Corrective Action Plan: Regarding internal controls over the FFATA (Federal Funding Accountability and Transparency Act) reporting, although no formal approval record could be provided, program staff reported that FFATA reports were verbally reviewed through one-on-one discussions. As recommended, the County will revise its internal FFATA reporting procedures to require that all FFATA submissions undergo a documented review and approval by an individual who is independent of the preparer. The procedures will be updated to require that the reviewer’s name, title, date of review, and confirmation of the reviewer’s approval be maintained in the program’s electronic records. The County will implement a standardized approval workflow—either through a designated electronic form, checklist, or approval routing mechanism—to ensure consistency across departments. Additionally, staff responsible for FFATA preparation and review will receive updated guidance and training on the new documentation requirements, The County will also evaluate opportunities to integrate this control into existing financial reporting and monitoring structures overseen by Housing and Community Development Services (HCDS) teams, to ensure consistent application of the updated approval requirements across reporting cycles. Anticipated Implementation Date: Updated procedures, workflow documentation, and staff training will be completed by June 30, 2026. Person Responsible: KELLY SALMONS, Deputy Director, Housing and Community Development Services

Categories

Subrecipient Monitoring Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1203056 2025-002
    Material Weakness Repeat
  • 1203057 2025-002
    Material Weakness Repeat
  • 1203058 2025-002
    Material Weakness Repeat
  • 1203059 2025-002
    Material Weakness Repeat
  • 1203060 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $103.52M
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $89.53M
93.563 CHILD SUPPORT SERVICES $37.07M
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $19.53M
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $7.80M
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $5.85M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $5.77M
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $5.27M
93.268 COVID-19 IMMUNIZATION COOPERATIVE AGREEMENTS $5.22M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $4.55M
14.879 MAINSTREAM VOUCHERS $3.51M
14.239 COVID-19 HOME INVESTMENT PARTNERSHIPS PROGRAM $3.34M
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $3.33M
93.391 COVID-19 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $2.77M
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $2.55M
93.917 HIV CARE FORMULA GRANTS $2.21M
16.922 EQUITABLE SHARING PROGRAM $2.15M
93.778 MEDICAL ASSISTANCE PROGRAM $1.99M
93.569 COMMUNITY SERVICES BLOCK GRANT $1.90M
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $1.76M
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $1.67M
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $1.53M
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $1.52M
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $1.50M
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $1.38M
93.667 SOCIAL SERVICES BLOCK GRANT $1.06M
10.720 INFRASTRUCTURE INVESTMENT AND JOBS ACT COMMUNITY WILDFIRE DEFENSE GRANTS $1.05M
93.495 COVID-19 COMMUNITY HEALTH WORKERS FOR PUBLIC HEALTH RESPONSE AND RESILIENT $851,642
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $738,651
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM APS COVID Admin $697,086
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $692,978
93.686 ENDING THE HIV EPIDEMIC: A PLAN FOR AMERICA — RYAN WHITE HIV/AIDS PROGRAM PARTS A AND B $676,812
93.304 RACIAL AND ETHNIC APPROACHES TO COMMUNITY HEALTH $649,973
14.856 LOWER INCOME HOUSING ASSISTANCE PROGRAM SECTION 8 MODERATE REHABILITATION $618,843
93.959 COVID-19 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $618,568
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $576,115
93.659 ADOPTION ASSISTANCE $563,787
16.606 STATE CRIMINAL ALIEN ASSISTANCE PROGRAM $542,734
93.977 COVID-19 SEXUALLY TRANSMITTED DISEASES (STD) PREVENTION AND CONTROL GRANTS $539,873
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $505,199
97.039 HAZARD MITIGATION GRANT $503,497
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $458,519
93.052 COVID-19 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $442,907
10.730 COMMUNITY PROJECT FUNDS - CONGRESSIONALLY DIRECTED SPENDING $419,967
16.U04 Immigration and Customs Enforcement (ICE) $391,150
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $358,397
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $330,676
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $306,029
16.U06 Narcotic Task Force (NTF) Drug Enforcement Agency (DEA) $299,515
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $287,045
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $285,807
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $278,270
14.880 FAMILY UNIFICATION PROGRAM (FUP) $270,434
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $270,114
10.427 RURAL RENTAL ASSISTANCE PAYMENTS $254,416
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $253,992
16.590 GRANTS TO ENCOURAGE ARREST POLICIES AND ENFORCEMENT OF PROTECTION ORDERS PROGRAM $250,176
93.322 CDC PARTNERSHIP: STRENGTHENING PUBLIC HEALTH LABORATORIES $247,000
93.590 COMMUNITY-BASED CHILD ABUSE PREVENTION GRANTS $230,299
14.872 PUBLIC HOUSING CAPITAL FUND $226,876
93.899 MINORITY HIV/AIDS FUND (MHAF) $216,752
16.U03 Domestic Cannabis Eradication and Suppression (DCE/SP) 2024 $215,794
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $209,507
93.603 ADOPTION AND LEGAL GUARDIANSHIP INCENTIVE PAYMENTS PROGRAM $197,897
16.U03 Domestic Cannabis Eradication and Suppression (DCE/SP) 2025 $189,537
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $187,986
66.472 BEACH MONITORING AND NOTIFICATION PROGRAM IMPLEMENTATION GRANTS $186,278
14.218 COVID-19 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $177,204
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED $174,030
93.493 CONGRESSIONAL DIRECTIVES $168,833
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $167,065
93.323 COVID-19 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $165,767
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $149,369
93.658 FOSTER CARE TITLE IV-E $147,265
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $144,671
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $136,028
93.043 COVID-19 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $134,032
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $115,967
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $114,150
10.025 PLANT AND ANIMAL DISEASE, PEST CONTROL, AND ANIMAL CARE $113,855
20.205 HIGHWAY PLANNING AND CONSTRUCTION $113,572
94.002 AMERICORPS SENIORS RETIRED AND SENIOR VOLUNTEER PROGRAM (RSVP) 94.002 $107,240
16.528 ENHANCED TRAINING AND SERVICES TO END VIOLENCE AND ABUSE OF WOMEN LATER IN LIFE $99,641
93.324 STATE HEALTH INSURANCE ASSISTANCE PROGRAM $97,593
16.U08 SAFE Streets - North County Regional Gang Task Force (NCRGTF) $95,513
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $89,927
16.742 PAUL COVERDELL FORENSIC SCIENCES IMPROVEMENT GRANT PROGRAM $87,009
14.850 PUBLIC HOUSING OPERATING FUND $86,867
16.U11 U.S Marshals Fugitive Task Force $85,086
66.701 TOXIC SUBSTANCES COMPLIANCE MONITORING COOPERATIVE AGREEMENTS $82,470
93.969 PPHF GERIATRIC EDUCATION CENTERS $80,000
93.354 COVID-19 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $79,502
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $65,907
93.090 GUARDIANSHIP ASSISTANCE $65,906
90.401 HELP AMERICA VOTE ACT REQUIREMENTS PAYMENTS $56,000
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $50,191
16.543 MISSING CHILDREN'S ASSISTANCE $49,788
16.U08 SAFE Streets - East County Regional Gang Task Force (ECRGTF) $48,207
93.070 ENVIRONMENTAL PUBLIC HEALTH AND EMERGENCY RESPONSE $39,972
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $39,220
93.045 COVID-19 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $35,320
97.067 HOMELAND SECURITY GRANT PROGRAM $32,000
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $29,530
10.555 NATIONAL SCHOOL LUNCH PROGRAM $26,323
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $24,062
16.U08 SAFE Streets - Violent Crimes Task Force (Gang Group) $21,740
16.U05 Joint Terrorism Task Force (JTTF) $19,625
93.071 MEDICARE ENROLLMENT ASSISTANCE PROGRAM $19,408
10.553 SCHOOL BREAKFAST PROGRAM $17,960
16.U01 Child Exploitation Task Force (CETF) $17,930
16.741 DNA BACKLOG REDUCTION PROGRAM $14,487
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $10,169
21.016 EQUITABLE SHARING $9,542
16.U10 San Diego Transnational Organized Crime Task Force $8,268
16.U08 SAFE Streets - Violent Crimes Task Force (Bank Robbery) $4,964
16.U09 San Diego North County Elder Justice Task Force $3,189
16.U02 Cyber Crimes Task Force (CCTF) $1,047
16.U07 Organized Crime Drug Enforcement Task Force (OCDETF) $666
16.036 COMPREHENSIVE FORENSIC DNA ANALYSIS GRANT PROGRAM $521
97.143 PRE-DISASTER MITIGATION (PDM) CONGRESSIONALLY DIRECTED SPENDING (CDS) $302
17.225 COVID-19 UNEMPLOYMENT INSURANCE $247
16.575 CRIME VICTIM ASSISTANCE $13