Finding Text
Federal Program AL No. 97.036 - COVID-19 Disaster Grants- Public Assistance (Presidentially Declared Disasters) Federal Agency U.S. Department of Homeland Security- Federal Emergency Management Agency Federal Award Number and Award Year 4486DR-FL and January 1, 2024 to December 31, 2024 Criteria Activities Allowed or Unallowed and Allowable Costs/Cost Principles Per FEMA’s Public Assistance Program and Policy Guide, this criterion applies to all costs claimed. Not all costs incurred as a result of the incident are eligible. To be eligible, costs must be: • Directly tied to the performance of eligible work; • Adequately documented (2 CFR 200.403(g)); • Reduced by all applicable credits, such as insurance proceeds and salvage values (Stafford Act Section 312, 42 USC Section 5155, and 2 CFR 200.406); • Authorized and not prohibited under Federal or SLTT government laws or regulations; • Consistent with the Applicant’s internal policies, regulations, and procedures that apply uniformly to both Federal awards and other activities of the Applicant; and • Necessary and reasonable to accomplish the work properly and efficiently (2 CFR 200.403). Special Tests and Provisions – Project Accounting For large projects, the recipient is required to make an accounting to FEMA of eligible costs. Similarly, the subrecipient must make an accounting to the recipient. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project is in compliance with the provisions of the FEMA-State Agreement, all grant conditions were met, and that payments for that project were made in accordance with the applicable payment provisions. For improved and alternate projects, if the total cost of the projects does not equal or exceed the approved eligible costs, then the auditor should expect to see an adjustment to reduce eligible costs (44 CFR section 206.205). Internal Control Additionally, 2 CFR 200.303 requires non-federal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition and Context On December 9, 2024, FEMA obligated Project Worksheet #674964 in the amount of $4,644,457. This amount included $209,763 of duplicate invoices. In July 2025, the Homeland Security Operational Analysis Center (HSOAC) issued an Applicant Review Memorandum indicating that it had evaluated Project Worksheet #674964 and determined that the methodology used by management to calculate a portion of the estimated expenditures was not reasonable, as the population included two duplicate invoices. As a result of these findings, FEMA subsequently deobligated $209,763. The Organization had a control in place over the compilation and review of expenditures submitted to FEMA for reimbursement that was appropriately designed to detect duplicate expenditures. However, the control did not operate effectively, as the review was not performed with sufficient rigor to identify and remove duplicate invoices prior to submission. Consequently, duplicate expenditures were included in the reimbursement request submitted to FEMA. Possible Cause and Effect The Organization had established a review control over expenditures submitted to FEMA for reimbursement that was designed to identify and prevent duplicate expenditures from being included in reimbursement requests. However, the control did not operate effectively, resulting in two duplicate expenditures totaling approximately $209,000 being included in a reimbursement request submitted to FEMA. The duplicate expenditures were subsequently identified during the HSOAC review process and were deobligated. Questioned Costs $209,763 Statistically Valid Sample Not applicable Repeat of Prior Finding Not a repeat finding. Recommendations We recommend that the Organization strengthen controls over the preparation and management review of FEMA reimbursement submissions to ensure duplicate invoices are identified and excluded, unallowable costs are not included, and all relevant supporting documentation is maintained in accordance with Federal requirements. View of Responsible Official Management agrees with the noted finding.