Finding Text
2023 SINGLE AUDIT FINDING SA-3: Compliance Element: Period of Performance Federal Department – Department of the Treasury COVID-19 - Provider Relief Fund and American Rescue Plan (ARPA) Coronavirus State and Local Fiscal Recovery Fund Federal Assistance Listing # 21.027 County Department – County Board CRITERIA: Recipients may only use funds to cover costs incurred during the period beginning on March 3, 2021 and ending on December 31, 2024, pursuant to the Final Rule at 31 CFR section 35.5(a). Recipients must liquidate all obligations incurred by December 31, 2024, under the award no later than December 31, 2026, which is the end of the period of performance. As such, program obligations or costs must be incurred from the period beginning on March 3, 2021 and ending on December 31, 2024. No new obligations or costs may be incurred during the period beginning January 1, 2025 and ending on December 31, 2026. During this two-year period from January 1, 2025, through December 31, 2026, recipients are only permitted to expend funds to satisfy obligations incurred by December 31, 2024. CONDITION: During the current audit period, the County did not receive verifications from subrecipients affirming final projected completion dates by December 31, 2026. CAUSE: Based on discussions with management, the cause of this finding was a lack of familiarity and awareness regarding the requirements to perform subrecipient monitoring, including the period of performance, in accordance with Federal regulations. EFFECT: Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards for projects that cannot be completed by December 31, 2026. QUESTIONED COSTS: None. CONTEXT: During the current audit period, we noted multiple subrecipients were awarded funds. During our review of the subrecipients, we noted adequate documentation was not maintained to support the period of performance required by Federal regulations. IDENTIFICATION OF REPEATED FINDINGS: None. RECOMMENDATION: We recommend that the County review the allowable costs principles and consult with the grant body to determine if grant repayment is required. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS: See corrective action plan. ANCITPATED COMPLETION DATE: See corrective action plan.