Finding 1229621 (2023-011)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2026-09-11
Audit: 410871
Auditor: BDO USA PC

AI Summary

  • Core Issue: Subrecipient agreements lack clear identification of federal program details and compliance requirements, leading to potential noncompliance.
  • Impacted Requirements: Violations of 2 CFR 200.303 and 200.332 regarding internal controls and subrecipient monitoring.
  • Recommended Follow-Up: Management should implement policies to ensure subawards meet federal requirements and establish monitoring procedures for subrecipient audits.

Finding Text

Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control Over Compliance Agency/Passthrough Grantor Department of the Treasury ALN and Program Name 21.027 - Coronavirus State and Local Fiscal Recovery Funds – COVID 19 Award # 1505-0271 Criteria or Specific Requirement The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.332 requires pass-through entities to ensure that subrecipients comply with the terms and conditions of 2 CFR 200.501 related to audit requirements. This includes ensuring that every subaward is (1) clearly identified to the subrecipient as a subaward; (2) includes the necessary information at the time of the subaward for subrecipient reporting on federal awards (2 CFR 200.332) and (3) includes requirement to follow 2 CFR 200.501 if expenditure thresholds are met. This also includes verifying that every subrecipient is audited as required by 2 CFR Subpart F if the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Condition During our testing of subrecipient monitoring, we noted all 10 of the subrecipient agreements tested did not include language clearly identifying the federal program from which the subaward originated, or the applicable requirements from 2 CFR 300.332 and Subpart F. We also noted for all 10 subrecipients tested that Anchorage did not verify whether subrecipients were audited in accordance with 2 CFR 200.501 where applicable. Cause The issuance of subrecipient agreements for these grants related to new funding streams in response to the COVID-19 pandemic. Significant amounts of funding were provided in a short period of time, and systems to distribute these monies were newly created and implemented. The standard award agreements were not reviewed in advance to ensure adherence to federal requirements. Staff were not fully trained on the informational requirements and monitoring responsibilities related to audit requirements. Effect or Potential Effect Subrecipients may be unaware and not in compliance with the requirements of 2 CFR Part 200. Questioned Costs Not applicable. Context A sample of 24 subawards were selected for testing totaling current year expenditures of $8,379,572 from a population of 24 subawards totaling $11,674,690. Exceptions were identified for all 10 subrecipient agreements tested. All samples tested were selected using nonstatistical sampling methods and were not statistically valid samples. Identification as a Repeat Finding Yes. This finding was reported as Finding 2022-009 in the prior year audit. Recommendation Management should establish policies to ensure subawards contain required federal award information. In addition, procedures should be established to monitor subrecipient compliance with audit requirements of 2 CFR 200.501. Views of Responsible Officials Management concurs with the finding and has begun revising policies and procedures related to subrecipient monitoring.

Corrective Action Plan

Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control Over Compliance Corrective Action Plan: The Municipality has begun implementing standardized subrecipient monitoring procedures, including documented risk assessments, monitoring protocols, supervisory review, and enhanced oversight to strengthen compliance with Uniform Guidance requirements. Management will evaluate the effectiveness of these controls through completion of a full audit cycle. Anticipated Completion Date June 30, 2027

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1229588 2023-009
    Material Weakness Repeat
  • 1229589 2023-009
    Material Weakness Repeat
  • 1229590 2023-009
    Material Weakness Repeat
  • 1229591 2023-009
    Material Weakness Repeat
  • 1229592 2023-009
    Material Weakness Repeat
  • 1229593 2023-009
    Material Weakness Repeat
  • 1229594 2023-010
    Material Weakness Repeat
  • 1229595 2023-010
    Material Weakness Repeat
  • 1229596 2023-010
    Material Weakness Repeat
  • 1229597 2023-010
    Material Weakness Repeat
  • 1229598 2023-010
    Material Weakness Repeat
  • 1229599 2023-010
    Material Weakness Repeat
  • 1229600 2023-010
    Material Weakness Repeat
  • 1229601 2023-010
    Material Weakness Repeat
  • 1229602 2023-010
    Material Weakness Repeat
  • 1229603 2023-010
    Material Weakness Repeat
  • 1229604 2023-010
    Material Weakness Repeat
  • 1229605 2023-010
    Material Weakness Repeat
  • 1229606 2023-010
    Material Weakness Repeat
  • 1229607 2023-010
    Material Weakness Repeat
  • 1229608 2023-010
    Material Weakness Repeat
  • 1229609 2023-010
    Material Weakness Repeat
  • 1229610 2023-010
    Material Weakness Repeat
  • 1229611 2023-010
    Material Weakness Repeat
  • 1229612 2023-010
    Material Weakness Repeat
  • 1229613 2023-010
    Material Weakness Repeat
  • 1229614 2023-010
    Material Weakness Repeat
  • 1229615 2023-010
    Material Weakness Repeat
  • 1229616 2023-010
    Material Weakness Repeat
  • 1229617 2023-010
    Material Weakness Repeat
  • 1229618 2023-010
    Material Weakness Repeat
  • 1229619 2023-010
    Material Weakness Repeat
  • 1229620 2023-010
    Material Weakness Repeat
  • 1229622 2023-012
    Material Weakness Repeat
  • 1229623 2023-012
    Material Weakness Repeat
  • 1229624 2023-012
    Material Weakness Repeat
  • 1229625 2023-012
    Material Weakness Repeat
  • 1229626 2023-012
    Material Weakness Repeat
  • 1229627 2023-012
    Material Weakness Repeat
  • 1229628 2023-012
    Material Weakness Repeat
  • 1229629 2023-012
    Material Weakness Repeat
  • 1229630 2023-012
    Material Weakness Repeat
  • 1229631 2023-012
    Material Weakness Repeat
  • 1229632 2023-012
    Material Weakness Repeat
  • 1229633 2023-012
    Material Weakness Repeat
  • 1229634 2023-012
    Material Weakness Repeat
  • 1229635 2023-012
    Material Weakness Repeat
  • 1229636 2023-012
    Material Weakness Repeat
  • 1229637 2023-012
    Material Weakness Repeat
  • 1229638 2023-012
    Material Weakness Repeat
  • 1229639 2023-012
    Material Weakness Repeat
  • 1229640 2023-012
    Material Weakness Repeat
  • 1229641 2023-012
    Material Weakness Repeat
  • 1229642 2023-012
    Material Weakness Repeat
  • 1229643 2023-012
    Material Weakness Repeat
  • 1229644 2023-012
    Material Weakness Repeat
  • 1229645 2023-012
    Material Weakness Repeat
  • 1229646 2023-012
    Material Weakness Repeat
  • 1229647 2023-012
    Material Weakness Repeat
  • 1229648 2023-012
    Material Weakness Repeat
  • 1229649 2023-012
    Material Weakness Repeat
  • 1229650 2023-012
    Material Weakness Repeat
  • 1229651 2023-012
    Material Weakness Repeat
  • 1229652 2023-012
    Material Weakness Repeat
  • 1229653 2023-012
    Material Weakness Repeat
  • 1229654 2023-012
    Material Weakness Repeat
  • 1229655 2023-012
    Material Weakness Repeat
  • 1229656 2023-012
    Material Weakness Repeat
  • 1229657 2023-012
    Material Weakness Repeat
  • 1229658 2023-012
    Material Weakness Repeat
  • 1229659 2023-012
    Material Weakness Repeat
  • 1229660 2023-012
    Material Weakness Repeat
  • 1229661 2023-012
    Material Weakness Repeat
  • 1229662 2023-012
    Material Weakness Repeat
  • 1229663 2023-012
    Material Weakness Repeat
  • 1229664 2023-012
    Material Weakness Repeat
  • 1229665 2023-012
    Material Weakness Repeat
  • 1229666 2023-012
    Material Weakness Repeat
  • 1229667 2023-012
    Material Weakness Repeat
  • 1229668 2023-012
    Material Weakness Repeat
  • 1229669 2023-012
    Material Weakness Repeat
  • 1229670 2023-012
    Material Weakness Repeat
  • 1229671 2023-012
    Material Weakness Repeat
  • 1229672 2023-012
    Material Weakness Repeat
  • 1229673 2023-012
    Material Weakness Repeat
  • 1229674 2023-012
    Material Weakness Repeat
  • 1229675 2023-013
    Material Weakness Repeat
  • 1229676 2023-013
    Material Weakness Repeat
  • 1229677 2023-013
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $46.33M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $16.97M
97.083 STAFFING FOR ADEQUATE FIRE AND EMERGENCY RESPONSE (SAFER) $1.15M
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $1.04M
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $961,713
20.505 METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON-METROPOLITAN PLANNING AND RESEARCH $848,422
20.933 NATIONAL INFRASTRUCTURE INVESTMENTS $838,032
93.778 MEDICAL ASSISTANCE PROGRAM $800,550
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $772,339
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $568,064
97.056 PORT SECURITY GRANT PROGRAM $456,876
16.835 BODY WORN CAMERA POLICY AND IMPLEMENTATION $446,980
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $419,266
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $303,242
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $258,807
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $254,661
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $239,605
20.507 FEDERAL TRANSIT FORMULA GRANTS $227,145
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $221,656
16.543 MISSING CHILDREN'S ASSISTANCE $216,529
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $189,001
16.922 EQUITABLE SHARING PROGRAM $186,706
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $178,229
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $151,829
14.881 MOVING TO WORK DEMONSTRATION PROGRAM $147,323
20.823 PORT INFRASTRUCTURE DEVELOPMENT PROGRAM $141,569
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $129,008
16.320 SERVICES FOR TRAFFICKING VICTIMS $120,779
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $118,243
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $103,268
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $74,291
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $71,974
97.067 HOMELAND SECURITY GRANT PROGRAM $49,941
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $49,411
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $44,353
45.310 GRANTS TO STATES $38,116
14.275 HOUSING TRUST FUND $24,053
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $23,472
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $21,818
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $17,306
20.526 BUSES AND BUS FACILITIES FORMULA, COMPETITIVE, AND LOW OR NO EMISSIONS PROGRAMS $16,559
20.205 HIGHWAY PLANNING AND CONSTRUCTION $13,388
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $8,193
93.103 FOOD AND DRUG ADMINISTRATION RESEARCH $3,297
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $-4,305
97.039 HAZARD MITIGATION GRANT $-12,269
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED $-14,956
10.664 COOPERATIVE FORESTRY ASSISTANCE $-22,369
15.916 OUTDOOR RECREATION ACQUISITION, DEVELOPMENT AND PLANNING $-157,461