Finding Text
Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Condition: All Emergency Rental Assistance (ERA) grantees must submit monthly and quarterly reports. Monthly reports capture details specific to that month while quarterly reports contain several cumulative fields covering all activity from the date of the grant award through the quarter close. These reports provide financial and performance data regarding grantee administration of their ERA projects and capture program design in addition to program status data elements. Quarterly reports are intended to capture standard financial and performance data, as well as detailed information on qualifying direct and indirect expenditures pursuant to the government-wide Federal Funding Accountability and Transparency Act (FFATA) reporting requirements and in accordance with Section 15011 of the Coronavirus Aid, Relief, and Economic Security Act, as amended and interpreted in the U.S. Department of Treasury?s reporting and compliance guidance on Treasury.gov. The reports submitted by the Organization to the Sonoma County Community Development Commission inaccurately reported total expenditures to date due to a formula error. However, monthly expenditures reported and claimed for reimbursement were determined to be accurate. Cause: Internal controls over preparation of complete and accurate reporting were not properly implemented. Effect: The Organization reflected inaccurate information in the report submitted to the Sonoma County Community Development Commission. Questioned Cost: Not applicable. Recommendation: We recommend that the Organization develop and implement a more robust system for the preparation and submission of reporting data. The process should include a secondary review and approval of the report and underlying data by someone other than the preparer. Views of Responsible Officials: See Corrective Action Plan