Finding 1227364 (2025-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-08-19
Audit: 409454
Organization: Town of Highgate, Vermont (VT)

AI Summary

  • Core Issue: The Town failed to submit required semi-annual SF-425 reports for two reporting periods, leading to non-compliance with federal guidelines.
  • Impacted Requirements: Compliance with 2 CFR Section 200.328 and grant agreement terms, which mandate timely submission of financial reports.
  • Recommended Follow-Up: Establish a formal grant tracking system and assign specific staff in the Finance Department to ensure timely preparation and submission of reports.

Finding Text

Classification: Material Weakness in Internal Control Over Compliance/Instance of Noncompliance Federal Awarding Agency: U.S. Department of Commerce Federal Program: Investments for Public Works and Economic Development Facilities Assistance Listings Number (ALN): 11.300 Federal Award Number and Year: 01-01-15333 (2022) Repeat Finding: No Statistically Valid Sample: No (Sample size: 0 reports tested; Universe size: 2 reports required) Subject: Failure to File Required Semi-Annual SF-425 Reports Criteria: In accordance with 2 CFR Section 200.328 and the specific grant award terms and conditions, grant recipients must monitor their federally sponsored activities to ensure compliance with applicable federal requirements. The grant agreement mandates the submission of a Standard Form 425 (SF-425) Federal Financial Report on a semi-annual basis. These reports are due no later than 30 calendar days after the end of each semi-annual reporting period. Condition: The Town did not submit any of the required semi-annual SF-425 Federal Financial Reports for the reporting periods ending September 30, 2024, and March 31, 2025. Out of a total universe of 2 required financial reports for the fiscal year, 0 were filed or available for testing. Cause: The failure to submit the reports was caused by a lack of internal controls and assigned staff oversight regarding grant reporting requirements. Effect: The Town is in non-compliance with federal reporting guidelines under Uniform Guidance. Failing to submit required financial reports prevents the federal awarding agency from monitoring the financial progress of the award. This can lead to a suspension of grant drawdowns or a withholding of future federal funding allocations. Questioned Costs: None noted. No unallowable expenditures were identified during testing but the necessary administrative transparency was compromised. Recommendation: We recommend that the Town implement a formalized grant tracking system that records all key filing deadlines upon award acceptance. Management should explicitly assign the responsibility of preparing, reviewing, and submitting the SF-425 reports to specific personnel within the Finance Department to ensure timely reporting compliance moving forward.

Corrective Action Plan

The Town of Highgate has endured a significant amount of turnover in the Town Administrator's role. This reporting was a task of the Town Administrator. The Town Treasurer was unaware that the SF-425 reports for the Town's active grant awards were not being filed in a timely fashion. The newly appointed Town Administrator has been made aware we are required to file the SF-425 when a grant award mandates the submission. Corrective action has began, the Town Administrator and Treasurer have been working together to get in compliance with our required reporting across all State and Federal Agencies that have awarded the Town grant funds. Trainings have taken place and the newly hired Administrator is aware of the required reporting and is able to perform this task on time when required.

Categories

Reporting Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
11.300 INVESTMENTS FOR PUBLIC WORKS AND ECONOMIC DEVELOPMENT FACILITIES $1.28M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $457,359
97.039 HAZARD MITIGATION GRANT $343,353
90.601 NORTHERN BORDER REGIONAL DEVELOPMENT $300,570
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $10,627
97.047 BRIC: BUILDING RESILIENT INFRASTRUCTURE AND COMMUNITIES $2,458