FAC Explorer

Finding 1316 (2022-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-11-07
Audit: 2473
Organization: St. Louis County, Missouri (MO)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The County failed to file FFATA reports for the 2022 award year due to unawareness of the reporting requirement.
  • Impacted Requirements: Compliance with FFATA mandates for reporting subawards of $30,000 or more, which is crucial for maintaining federal funding.
  • Recommended Follow-Up: Implement a tracking process for timely FFATA submissions, provide employee training on reporting requirements, and establish compliance procedures for federal awards.

Finding Text

2022-001 FFATA reporting Federal Agency U.S. Department of Housing and Urban Development Federal Program Name Community Development Block Grant-Entitlement Grants Cluster Assistance Listing Number 14.218 Federal Award Identification Number and Year: B-15-UC-29-2001, 2015; B-17-UC-29-0001, 2017; B-19-UC-29-0001, 2019; B-20-UW-29-0001, 2020; B-20-UC-29-0001, 2020; B-21-UC-29-0001, 2021 Award Period September 27, 2016 – September 1, 2028 Pass-through Entity N/A Questioned Costs None Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement Under the requirements of the Federal Funding Accountability and Transparency (FFATA) Office (Pub. L. No. 109-282) as amended by Section 6202 of Public Law 110-252, recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. The County must establish and maintain effective internal controls over federal awards that provides reasonable assurance that they are managing federal awards in compliance with federal statutes, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Condition and Context During testing of the Federal Funding Accountability and Transparency Act (FFATA) reporting, it was noted that the report was not filed for the 2022 award year. The County has one subrecipient requiring FFATA reporting. Cause The County was unaware of the FFATA reporting requirement. Effect Failure to comply with reporting requirements could result in loss of future funding. Recommendation We recommend the County implement a process and control that includes tracking and approving timely submission of the FFATA reports as well as training employees on the FFATA reporting requirements. Repeat Finding No Views of Responsible Officials There is no disagreement with the audit finding. The Director of Department of Human Services shall work with his management team to develop and execute a plan to (1) Communicate with the U.S. Department of Housing and Urban Development to determine whether and how St. Louis County can update and submit the Federal Funding Accountability and Transparency Act (FFATA) reporting of the Community Development Block Grants for expenditure year 2022 by December 31, 2023. (2) Establish department compliance procedures to communicate and manage federal awards to ensure compliance with laws, statutes, regulations, rules, and provisions of contracts or grant agreements applicable to St. Louis County, Missouri’s federal programs. (3) Define and communicate required yearly grant management training and ensure training completion is timely and records are kept. (4) Establish quality controls and monitoring processes to ensure accurate accounting, reconciliations, tracking, and timely reporting.

Corrective Action Plan

There is no disagreement with the audit finding. The Director of Department of Human Services shall work with his management team to develop and execute a plan to (1) Communicate with the U.S. Department of Housing and Urban Development to determine whether and how St. Louis County can update and submit the Federal Funding Accountability and Transparency Act (FFATA) reporting of the Community Development Block Grants for expenditure year 2022 by December 31, 2023. (2) Establish department compliance procedures to communicate and manage federal awards to ensure compliance with laws, statutes, regulations, rules, and provisions of contracts or grant agreements applicable to St. Louis County, Missouri’s federal programs. (3) Define and communicate required yearly grant management training and ensure training completion is timely and records are kept. (4) Establish quality controls and monitoring processes to ensure accurate accounting, reconciliations, tracking, and timely reporting.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1317 2022-001
    Significant Deficiency
  • 1318 2022-001
    Significant Deficiency
  • 1319 2022-001
    Significant Deficiency
  • 1320 2022-001
    Significant Deficiency
  • 1321 2022-001
    Significant Deficiency
  • 1322 2022-001
    Significant Deficiency
  • 1323 2022-001
    Significant Deficiency
  • 1324 2022-001
    Significant Deficiency
  • 577758 2022-001
    Significant Deficiency
  • 577759 2022-001
    Significant Deficiency
  • 577760 2022-001
    Significant Deficiency
  • 577761 2022-001
    Significant Deficiency
  • 577762 2022-001
    Significant Deficiency
  • 577763 2022-001
    Significant Deficiency
  • 577764 2022-001
    Significant Deficiency
  • 577765 2022-001
    Significant Deficiency
  • 577766 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $34.91M
21.023 Emergency Rental Assistance Program $25.54M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $2.44M
17.258 Wia Adult Program $1.18M
17.278 Wia Dislocated Worker Formula Grants $978,481
93.563 Child Support Enforcement $799,038
93.767 Children's Health Insurance Program $640,712
20.218 National Motor Carrier Safety $591,245
20.615 E-911 Grant Program $495,712
16.922 Equitable Sharing Program $474,301
14.900 Lead-Based Paint Hazard Control in Privately-Owned Housing $380,584
93.495 Community Health Workers for Public Health Response and Resilient $378,973
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $329,311
20.106 Airport Improvement Program $327,091
97.091 Homeland Security Biowatch Program $300,387
16.754 Harold Rogers Prescription Drug Monitoring Program $278,254
93.940 Hiv Prevention Activities_health Department Based $274,438
93.069 Public Health Emergency Preparedness $245,520
20.205 Highway Planning and Construction $235,405
16.320 Services for Trafficking Victims $216,599
16.034 Coronavirus Emergency Supplemental Funding Program $215,780
66.001 Air Pollution Control Program Support $201,538
16.838 Comprehensive Opioid Abuse Site-Based Program $190,566
93.667 Social Services Block Grant $171,831
93.910 Family and Community Violence Prevention Program $151,656
16.827 Justice Reinvestment Initiative $141,063
93.217 Family Planning_services $132,789
16.588 Violence Against Women Formula Grants $128,358
14.218 Community Development Block Grants/entitlement Grants $121,273
16.021 Justice Systems Response to Families $119,248
16.817 Byrne Criminal Justice Innovation Program $117,719
16.738 Edward Byrne Memorial Justice Assistance Grant Program $95,384
17.277 Workforce Investment Act (wia) National Emergency Grants $93,710
21.016 Equitable Sharing $88,477
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $85,763
20.600 State and Community Highway Safety $85,296
93.136 Injury Prevention and Control Research and State and Community Based Programs $84,977
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $75,395
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $72,051
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $70,987
16.741 Dna Backlog Reduction Program $68,982
16.575 Crime Victim Assistance $64,342
16.029 Office on Violence Against Women Special Projects $60,021
93.575 Child Care and Development Block Grant $49,550
14.913 Healthy Homes Production Program $46,175
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $33,527
16.710 Public Safety Partnership and Community Policing Grants $30,564
93.558 Temporary Assistance for Needy Families $26,368
93.914 Hiv Emergency Relief Project Grants $21,680
20.616 National Priority Safety Programs $21,182
17.259 Wia Youth Activities $17,828
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $16,125
16.585 Drug Court Discretionary Grant Program $15,628
14.231 Emergency Solutions Grant Program $15,361
14.267 Continuum of Care Program $13,761
14.239 Home Investment Partnerships Program $13,653
93.268 Immunization Cooperative Agreements $11,671
10.559 Summer Food Service Program for Children $11,550
97.042 Emergency Management Performance Grants $11,380
20.607 Alcohol Open Container Requirements $10,052
93.103 Food and Drug Administration_research $9,506
16.736 Transitional Housing Assistance for Victims of Domestic Violence, Dating Violence, Stalking, Or Sexual Assault $9,446
93.539 Pphf Capacity Building Assistance to Strengthen Public Health Immunization Infrastructure and Performance Financed in Part by Prevention and Public Health Funds $8,896
14.248 Community Development Block Grants_section 108 Loan Guarantees $8,794
93.788 Opioid Str $8,109
16.593 Residential Substance Abuse Treatment for State Prisoners $6,887
17.201 Registered Apprenticeship $4,500
95.001 High Intensity Drug Trafficking Areas Program $3,960
97.067 Homeland Security Grant Program $3,534
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $2,936
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $2,147
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $2,077
93.994 Maternal and Child Health Services Block Grant to the States $1,054
21.019 Coronavirus Relief Fund $695
93.978 Preventive Health Services_sexually Transmitted Diseases Research, Demonstrations, and Public Information and Education Grants $464
93.070 Environmental Public Health and Emergency Response $361
93.435 Innovative State and Local Public Health Strategies to Prevent and Manage Diabetes and Heart Disease and Stroke- $148
15.658 Natural Resource Damage Assessment, Restoration and Implementation $2