Finding 23168 (2022-002)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-09-05
Audit: 23003
Organization: Boulder County, Colorado (CO)

AI Summary

  • Core Issue: The County failed to provide necessary documentation for reported amounts in financial reports, leading to a material weakness in internal controls.
  • Impacted Requirements: Non-federal entities must submit quarterly and monthly reports on time and maintain effective internal controls as per federal guidelines.
  • Recommended Follow-Up: Implement policies to ensure timely and accurate report submissions, with reviews by authorized officials to support reported figures.

Finding Text

2022 ? 002 Emergency Rental Assistance Reporting Prior Year Finding: N/A Federal Agency: Department of the Treasury Federal Program: COVID-19 ? Emergency Rental Assistance Assistance Listing Number: 21.023 Award Number and Period: ERA0279 (1/12/2021 ? 9/30/2022) ERAE0206 (5/10/2021 ? 9/30/2025) ERAE0299 (5/10/2021 ? 9/30/2025) Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Non-federal entities are required to submit quarterly SF-425 Financial Reports and quarterly Special Reports no later than 15 days after the end of each quarter, in accordance with the terms and conditions of the Federal award. On a monthly basis Non-federal entities are required to submit Monthly Reports no later than 15 days after the end of the month, in accordance with the terms and conditions of the Federal award. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County was not able to provide supporting documentation for their reported amounts. The County failed to retain data records for the point in time that was used to report each submission. As a result, reported key line items could not be supported. Questioned costs: None. Context: We reviewed a sample of the Quarterly SF-425 Financial Reports as well as the Monthly Special Reports and Quarterly Special Reports filed during FY2022. The following exceptions were noted: SF-425: For 2 of 2 quarters selected we reviewed the ERA-1 and ERA-2 required reports. We noted that supporting documentation could not be provided to substantiate that the reports were compiled accurately. Various amounts on the treasury submissions could not be tied back to any support. Monthly Report: For 1 of 4 ERA-1 & ERA-2 monthly reports reviewed, we noted that the ERA-1 report incorrectly entered the ?Number of households assisted? amount. The reported amount should have been 110 and 120 was reported. Quarterly Report: For 2 of 2 quarters selected we reviewed the ERA-1 and ERA-2 required reports. We noted that supporting documentation could not be provided to substantiate that the reports were compiled accurately. Key line items ?current quarter obligations?, ?current quarter expenditures?, ?cumulative obligations to date? and ?cumulative expenditures to date? could not be tied back to any support. Cause: Procedures and controls were insufficient to ensure that supporting documentation was maintained and available for audit and that reports were filed accurately. The reports are filed electronically, and the County did not maintain copies of all supporting documentation used to prepare SF-425, Monthly and Quarterly reports. Effect: Monthly and Quarterly data reported for the program was unable to be supported with adequate documentation. Recommendation: We recommend that policies and procedures be implemented to ensure that all financial and special reports are filed timely and accurately and that reports are reviewed and approved by an authorized State official prior to submission to ensure accurate support for the reported amounts. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

2022 ? 002 Emergency Rental Assistance ? Assistance Listing No. 21.023 Condition: The County was not able to provide supporting documentation for their reported amounts. The County failed to retain data records for the point in time that was used to report each submission. As a result, reported key line items could not be supported. Recommendation: We recommend that policies and procedures be implemented to ensure that all financial and special reports are filed timely and accurately and that reports are reviewed and approved by an authorized State official prior to submission to ensure accurate support for the reported amounts. Views of responsible officials and planned corrective actions: The county agrees with the finding will improve the process for reporting under the Emergency Rental Assistance program and retain documentation that supports the information reported. ERAP program management will provide supporting documentation for their reported amounts to the Federal Treasury moving forward. We have implemented corrective action in May 2023 for preparation and submission of the ERA2 2023 Q1 Treasury report. Responsible Official: Ramona Farineau, Chief Financial Officer Planned completion date for corrective action plan: May 31, 2023

Categories

Reporting Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 23167 2022-001
    Significant Deficiency
  • 599609 2022-001
    Significant Deficiency
  • 599610 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Covid 19-Coronavirus Local Fiscal Recovery Funds County Allocation Arpa $12.78M
21.023 Covid 19-Emergency Rental Assistance Rounds 1 and 2 $12.68M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters Fire) $11.32M
93.575 Child Care and Development Block Grant $5.91M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters Flood) $5.61M
93.558 Colorado Works / Temporary Assistance for Needy Families [tanf] $5.49M
93.658 Foster Care Title IV-E $3.85M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $3.61M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $3.11M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc-1) Fy21 $3.08M
97.047 Pre-Disaster Mitigation $3.03M
93.778 Medical Assistance Program Title Xix and Area on Aging $2.96M
93.563 Child Support Services $2.69M
93.568 Low-Income Home Energy Assistance Program Leap $1.74M
93.600 Head Start $1.46M
93.667 Social Services Block Grant Ssbg Title Xx $1.24M
93.659 Adoption Assistance Title IV-E $876,633
93.044 Special Programs for Aging Title III Part B Grants for Supportive Services and Senior Care $868,093
10.923 Natural Resources Conservation Services Emergency Watershed Program - Fa and Ta $664,297
93.243 Substance Abuse and Mental Health Services- Boulder County Housing and Human Services; Community Services $655,450
21.027 Covid 19-Coronavirus Aid, Relief, and Economic Security Act (cares Act), Cwdc Run, Innovation $633,700
93.569 Community Services Block Grant $563,843
93.045 Special Programs for Aging Title III Part C Nutrition Services $549,541
17.207 Employment Service/wagner-Peyser Funded Activities $467,410
15.226 Payments in Lieu of Taxes (pilt) $446,600
17.259 Wia Youth Activities $419,919
17.278 Edw Work Based Learning and Wia Dislocated Worker Formula Grant $388,684
17.258 Wia Adult Program and Py20 Zoma $322,423
16.575 Crime Victim Assistance $322,198
16.812 Office of Juvenile Justice Delinquency Prevention (ojjdp) Reentry $289,960
16.838 Comprehensive Opioid Abuse Site-Based Program, Cossap Project $285,600
93.994 Maternal and Child Health Services Care Coordination and Child Adolescent Program $282,208
16.034 Covid-19 20th Jd Da Coronavirus Justice Reform $262,467
93.052 Special Programs for Aging Title III Part E $257,227
93.959 Block Grants for Prevention and Treatment of Substance Abuse $209,421
10.244 Women Infant and Children Grants $204,835
17.268 Py21 Tecp $187,375
16.576 Crime Victim Compensation Fund $186,848
16.321 Antiterrorism Emergency Assistance Program (aeap) $183,536
93.674 Chafee Foster Care Independence Program Title IV-E $177,690
16.745 Criminal and Juvenile Justice and Mental Health Collaboration $162,391
93.556 Promoting Safe and Stable Families Pssf $143,555
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds, Substance Abuse, Behavioral Health $141,648
93.648 Family Support Through Primary Prevention (fspp) /community-Based Child Abuse Prevention Grants $138,060
93.645 Title IV-B Child Welfare State Grants $128,289
16.034 Covid-19 Jail Transitional Housing Assistance Program Cesf $122,634
16.838 Comprehensive Opioid Abuse Site-Based Program $120,612
93.268 Immunization Cooperative Agreements $113,512
93.276 Substance Abuse and Mental Health Services - Center for Substance Abuse Prevention $111,091
93.103 Retail Flexible Funding Model Grant Program $92,000
97.042 Emergency Management Performance Grants $89,784
17.277 CO Responds and Recover Colorado $87,460
93.136 Injury Prevention and Control Research and State and Community Based Programs $87,398
10.551 Supplemental Nutrition Assistance Program $86,923
14.169 Hud/housing Counseling $85,731
99.U19 Covid-19 Neighborworks America Housing Stability Counseling Program $83,682
16.528 Office on Violence Agenst Women (ovw) $80,034
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities Program (via Mobility) $73,549
16.838 Comprehensive Opioid, Stimulant, and Substance Abuse Program, Project Recovery $72,780
10.558 Child and Adult Care Food Program $70,522
17.225 Unemployment Insurance $68,668
93.324 State Health Insurance Assistance Program $63,937
16.738 Edward Byrne Memorial Justice Assistance Program, Blue Sky Pinwheel Project $60,656
16.590 Improving Criminal Justice Response to Domestic Violence, Dating Violence, Sexual Assault and Stalking Program $60,296
93.090 Guardianship Assistance $58,818
20.205 Highway Planning and Construction $55,768
14.218 Community Development Block Grant, Longmont Housing Counseling $50,000
14.228 Community Development Block Grants $50,000
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act Fy21 $46,423
93.317 Centers for Disease Control and Prevention-Investigations and Technical Assistance $42,628
16.606 State Criminal Alien Assistance Program $39,355
93.069 Public Health Emergency Preparedness $36,841
10.935 Urban Agriculture and Innovative Production-Farm to Table $36,204
93.421 Supporting and Enhancing the Environmental Health Workforce, Strategy 1 $32,495
93.747 Elder Abuse Prevention Interventions Program $31,635
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act Fy20 $31,393
97.039 Hazard Mitigation Emergency Management $31,029
93.043 Special Programs for Aging Title III Part D Disease Prevention and Health Promotion Services $28,845
66.717 Transitioning Food and Beverage Manufacturers to Pollution Reduced Packaging $24,215
17.801 Disabled Veteran's Outreach Program (dvop) $23,000
93.991 Preventative Health and Health Services Block Grant Fy22 $18,693
93.042 Special Programs for Aging Title Vii Chapter 2-Long Term Care Ombudsman Services for Older Individuals $17,698
16.543 Internet Crimes Against Children $15,900
14.231 Covid 19-Emergency Solutions Grant Program Cv Cares Act 21 $15,815
17.245 Trade Adjustment Assistance $14,849
21.016 Asset Forfeiture $14,455
17.280 Workforce Innovation and Opportunity Act Dislocated Worker National Reserve Demonstration Grants, Idea $12,164
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds, Healthy Eating $12,060
16.922 Department of Justice Equitable Sharing Funds-Asset Forfeiture $11,814
16.738 Fy 22 Justice Assistance Grant Program $9,880
93.670 Child Abuse and Neglect Discretionary Activities $7,689
93.439 Centers for Disease Control, State Physical Activity and Nutrition $5,465
66.444 Lead Testing in School and Child Care Program Drinking Water (sdwa 1464(d)) (a) $5,000
93.041 Special Programs for Aging Older Americans Title III and Title Vii $1,949
21.019 Covid 19-Coronavirus Aid, Relief, and Economic Security Act (cares Act), Hhs $-1,369