Finding 1237530 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-09-28

AI Summary

  • Core Issue: The District inaccurately reported FEMA Public Assistance expenditures on the SEFA, failing to consider the date FEMA approved funding, leading to misalignment in fiscal year reporting.
  • Impacted Requirements: This oversight affects compliance with federal reporting criteria, potentially altering the federal expenditures reported and impacting audit requirements under 2 CFR Part 200.
  • Recommended Follow-up: Implement controls to ensure both the date of incurred expenditures and FEMA obligation dates are documented, and maintain reconciliation to support accurate SEFA reporting.

Finding Text

Finding 2025-001 Timing of Recognition of FEMA Public Assistance Expenditures on the Schedule of Expenditures of Federal Awards Award Information Cluster: Not applicable Federal Granting Agency: Department of Homeland Security Award Name: Disaster Grants – Public Assistance Award Numbers: FEMA 4420-DR-NE, FEMA 4325-DR-NE, FEMA 4521-DR-NE, FEMA 4616-DR-NE, FEMA 4641-DR-NE, FEMA 4662-DR-NE Award Years: 2019-2023 Assistance Listing #: 97.036 Assistance Listing Title: Disaster Grants – Public Assistance Pass-through Entity: Nebraska Emergency Management Agency Criteria For Disaster Grants – Public Assistance, nonfederal entities are required to record expenditures on the Schedule of Expenditures of Federal Awards ("SEFA") when both (1) FEMA has approved the nonfederal entity's project and (2) the nonfederal entity has incurred the eligible expenditures. FEMA's approval of a subaward is indicated when FEMA obligates the federal share of the eligible project cost to the recipient. Condition Historically, the District's process for determining the timing of expenditures reported on its SEFA for Assistance Listing 97.036 considered the date eligible project expenditures were incurred following a federally declared disaster but did not consistently consider the date on which FEMA approved the related project by obligating the federal share of eligible project costs. As a result, certain eligible expenditures associated with FEMA Public Assistance projects were reported on the District's SEFAs in fiscal years prior to the fiscal year in which FEMA obligated the related federal funding. Management's retrospective analysis of the fiscal years 2019 through 2023 identified differences between expenditures historically reported on the SEFA and expenditures that would have been reported had the FEMA obligation date been considered in determining the appropriate reporting period. The underlying eligible project expenditures associated with these differences had been subject to audit in prior periods. Accordingly, the matter resulted in differences in the timing of reporting expenditures among fiscal years rather than identification of unallowable expenditures, and no questioned costs were identified. Cause The District's historical process for preparing the SEFA was based on an insufficient understanding of the program-specific reporting criteria applicable to FEMA Public Assistance expenditures and incorrect interpretation that eligible expenditures should be reported once the expenditures were incurred following declaration of a federal disaster and the District expected the project to subsequently qualify for FEMA reimbursement. Consequently, the process did not include a control requiring management to identify and consider the date FEMA obligated the federal share for each project when determining the fiscal year in which the related eligible expenditures should be reported on the SEFA. Effect Without a control that considers both the date eligible expenditures are incurred and the date FEMA approves the project through obligation of the federal share, expenditures related to FEMA Public Assistance projects could be reported on the SEFA in an incorrect fiscal year. Incorrect timing of SEFA recognition could affect the amount of federal expenditures reported for a fiscal year and, depending on the amount of expenditures affected, could also affect the District's determination of whether it is subject to the audit requirements of 2 CFR Part 200, Subpart F and the identification of programs subject to audit. Questioned Costs The matter did not result in questioned costs because the underlying project expenditures were incurred and were subject to audit in either fiscal year 2021 or 2022. Repeat Finding No Recommendation We recommend that the District maintain controls over preparation of the SEFA that require management, for each FEMA Public Assistance project, to identify and document both (1) the period in which eligible project expenditures were incurred and (2) the period in which FEMA approved the project by obligating the federal share. For expenditures incurred before FEMA obligation, the District should ensure that such expenditures are included on the SEFA in the fiscal year in which FEMA obligation occurs and that the SEFA includes the applicable disclosure of expenditures incurred in a prior fiscal year. Management should also maintain a reconciliation of eligible expenditures, FEMA obligations, amounts reported on the SEFA, and subsequent reimbursements to support the completeness and accuracy of SEFA reporting. Management’s Views and Planned Corrective Actions Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of prior audit findings and status.

Corrective Action Plan

2025-001 – Timing of Recognition of FEMA Public Assistance Expenditures on the Schedule of Expenditures of Federal Awards Award information Cluster: Not applicable Federal Granting Agency: Department of Homeland Security Award Name: Disaster Grants – Public Assistance Award Numbers: FEMA 4420-DR-NE, FEMA 4325-DR-NE, FEMA 4521-DR-NE, FEMA 4616-DR-NE, FEMA 4641-DR-NE, FEMA 4662-DR-NE Award Years: 2019-2023 Assistance Listing #: 97.036 Assistance Listing Title: Disaster Grants – Public Assistance Pass-through Entity: Nebraska Emergency Management Agency Management acknowledges that its historical process for determining the timing of FEMA Public Assistance expenditures reported on the SEFA was based on the date eligible expenditures were incurred following a federally declared disaster and did not consistently incorporate the date FEMA obligated the related federal funding. Management reached out to Nebraska Emergency Management Agency (“NEMA”) in March 18, 2026. Lynn Feeken, NPPD Controller, performed email communication with NEMA regarding the approach used for past Single audits. Specifically, management indicated that criteria used in 2023 and prior was to include eligible incurred costs upon Federal disaster declaration, assuming they would be approved by NEMA/FEMA. For calendar years 2024 and forward NPPD would consider 2 criteria: (1) FEMA approved the nonfederal entity’s (NPPD’s) project (also referred to as obligated) and (2) the nonfederal entity (NPPD) incurred the eligible expenditures. While not specifically addressing the quantitative discrepancies in the Schedule of Expenditures of Federal Awards (“SEFA”) stemming from the different approach applied, NPPD confirmed that NEMA has no issues with the revised criteria via email. Management has revised its process to determine SEFA-reportable expenditures based on both the date eligible expenditures are incurred and the date FEMA approves the related project through obligation of the federal share. Management applied this methodology in preparing the 2025 SEFA and will for future SEFAs and will maintain supporting documentation of eligible expenditures and FEMA obligations. Leadership Responsible: Laura Kapustka, Executive Vice President & Chief Financial Officer; Lynn Feeken, Controller, Chuck Keep, Asset Accounting & Miscellaneous Billing Supervisor Completion Date: 09/23/2026

Categories

Reporting Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $814,354
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $332,500
15.507 WATERSMART (SUSTAIN AND MANAGE AMERICA€™S RESOURCES FOR TOMORROW) $201,668
10.868 RURAL ENERGY FOR AMERICA PROGRAM $7,000