Finding Text
CSLFRF Performance Reporting Type of Finding Significant Deficiency - Internal Control Over Compliance New or Repeat Finding New Federal Program(s) COVID-19 - Coronavirus State and Local Fiscal Recovery Fund (ALN 21.027) Federal Agency U.S. Department of Treasury Pass-through Entity and Identifying Numbers N/A Compliance Requirement(s) L. Reporting Criteria The 2024 OMB Compliance Supplement for Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) requires recipients to submit the Project and Expenditure Report (P&E Report) on a quarterly or annual cycle, as applicable, pursuant to 2 CFR 200.328 and 31 CFR §35.4(c). The Department of Treasury’s reporting guidance specifies the required content and deadlines for each reporting cycle. Quarterly reporters must submit each P&E Report by the due date established in Treasury guidance to ensure timely oversight of obligations, expenditures, and project activity. Condition During our audit of the City’s CSLFRF (ALN 21.027), we noted that the City submitted the quarterly P&E Reports for December 31, 2023; March 31, 2024; and June 30, 2024, but did not submit the required report for the period ended September 30, 2024. As a result, activity for this period was not reported in the U.S. Department of the Treasury’s reporting portal as required. Cause The City did not have sufficiently formalized internal controls to consistently track CSLFRF reporting due dates and ensure timely preparation and submission of the quarterly P&E Report. Limited familiarity with Treasury’s reporting guidance and competing operational priorities contributed to the missed reporting deadline. Effect or Potential Effect Failure to submit required performance reports constitutes noncompliance with federal reporting requirements. Untimely or missing reports reduce transparency over program activity and may limit the Department of Treasury’s ability to evaluate obligations, expenditures, and project status. Although we did not identify questioned costs, the absence of timely reporting indicates that internal controls over compliance were not operating effectively, which supports a significant deficiency. Questioned Costs None Context The City submitted the first three quarterly reports for calendar year 2024; however, the September 30, 2024 report was not submitted. The City explained that staff turnover and transitions within the grants and finance functions contributed to challenges in tracking federal grant reporting deadlines. Recommendation We recommend the City put a simple process in place to track CSLFRF reporting deadlines, assign staff to prepare and review each quarterly report, and ensure staff have the guidance and training needed to submit complete and timely reports through the Department of Treasury’s portal. Views of Responsible Officials City officials agree with the finding. The City will strengthen internal controls over CSLFRF reporting, refine monitoring procedures for quarterly deadlines, and provide additional training to staff involved in preparing required reports.