Finding 28632 (2022-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-03-01

AI Summary

  • Core Issue: The County failed to provide the required performance narrative in quarterly reports for the Emergency Rental Assistance Program.
  • Impacted Requirements: Compliance with Treasury's reporting guidance, specifically the performance narrative detailing activities, achievements, challenges, and compliance issues.
  • Recommended Follow-Up: Create a template for the performance narrative to ensure all required elements are included in future reports, starting with the first quarterly report of 2023.

Finding Text

Finding 2022-001: US Department Treasury Emergency Rental Assistance Program CFDA Number: 21.023 Grant Award Number: Multiple Awards Compliance Requirement: Reporting Type of Finding: Significant deficiency in internal control over compliance Criteria: In the US Department of Treasury Reporting Guidance ? Emergency Rental Assistance Program, page 34, it requires recipients to provide a current performance narrative of 2,000 words or less describing the performance and accomplishments of the subject ERA project over the reporting period (which is quarterly). The narrative must include the following information: - Activities implemented and notable achievements over the calendar quarter - Activities planned for next quarter - Notable challenges and status of each challenge - Details on compliance/non-compliance issues and mitigation plans - Requests for additional assistance or guidance from Treasury - Other information, as appropriate. Condition: While the County complied with all other aspects of reporting for the program, the County did not comply with the performance reporting requirement noted above. This section of the quarterly reports submitted to Treasury were marked ?N/A?, and therefore lacked the required elements as listed above. Questioned Costs: None Context: As this is a new federal program (this is the second reporting year), the guidance from Treasury changed often. We observed that efforts were made to comply with reporting requirements, and this appeared to be an oversight. The quarterly reports were accepted by Treasury, with no further follow-up from them. Effect or Potential Effect: The effect of the noncompliance noted above is that it increases risk for action by the federal agency for contract noncompliance. Cause: Misunderstanding of grant contract performance reporting requirement. Recommendation: We recommend that the responsible report preparer create a template with the required reporting elements for the narrative portion. Each quarter the template can be updated with the appropriate wording, as required. In the User Guide ? Treasury?s Portal for Recipient Reporting, page 54, it suggests typing the information directly on screen or upload a document via the ?upload files? functionality on the website. We recommend this process begin with the first quarterly report filed in 2023, since all previously filed reports were accepted online and cannot be changed.

Categories

Internal Control / Segregation of Duties Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 28631 2022-001
    Significant Deficiency
  • 605073 2022-001
    Significant Deficiency
  • 605074 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.023 Emergency Rental Assistance Program $2.43M
17.278 Wia Dislocated Worker Formula Grants $1.08M
93.563 Child Support Enforcement $790,656
17.258 Wia Adult Program $672,683
17.259 Wia Youth Activities $623,321
15.916 Outdoor Recreation_acquisition, Development and Planning $412,500
20.205 Highway Planning and Construction $400,000
23.002 Appalachian Area Development $387,500
21.016 Equitable Sharing $232,316
16.579 Juvenile Arbitration $87,440
16.922 Equitable Sharing Program $29,901
16.588 Violence Against Women Formula Grants $20,336
93.889 National Bioterrorism Hospital Preparedness Program $19,903
97.042 Emergency Management Performance Grants $17,444
16.034 Coronavirus Emergency Supplemental Funding Program $13,597
16.738 Edward Byrne Memorial Justice Assistance Grant Program $7,423
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $6,983
14.239 Home Investment Partnerships Program $4,432
14.218 Community Development Block Grants/entitlement Grants $4,342
20.600 State and Community Highway Safety $1,350
16.606 State Criminal Alien Assistance Program $51