FAC Explorer

Finding 31148 (2022-001)

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Requirement
L
Questioned Costs
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Year
2022
Accepted
2023-08-29
Audit: 27596
Organization: City of San Bernardino (CA)
Auditor: Rogers Anderson Malody & Scott LLP

AI Summary

  • Core Issue: The City failed to report first-tier subawards of $50,000 or more to the FFATA Subaward Report System (FSRS) as required.
  • Impacted Requirements: Noncompliance with 2 CFR Part 170 and the compliance supplement, which mandates timely reporting of subawards.
  • Recommended Follow-Up: Implement a tracking system to ensure timely reporting of all required subawards and deadlines.

Finding Text

2022-001 ? Subaward Reporting Requirements for Federal Funding Accountability and Transparency Act (FFATA) Significant Deficiency and Non-Material Noncompliance Federal Program CDBG-Entitlement Grants Cluster, CFDA 14.218 Criteria The requirements of 2 CFR Part 170 Appendix A states that direct recipients of grants or cooperative agreements are required to report first-tier subawards of $50,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Report System (FSRS) by the end of the following month in which the direct recipient awards such subawards. Part 3 of the compliance supplement requires this reporting at the $30,000. Condition During the audit, we noted reporting of subaward information to FSRS was not performed. Cause The City did not have controls in place to ensure FSRS reporting was completed in the required timeframe. Identification as a Repeat Finding This is not a repeat finding. Effect The City could jeopardize future grant funding due to program noncompliance. Question Costs None. Recommendation We recommend the City implement a tracking system to remind staff of the various reports due and respective deadlines. Management?s Response See Corrective Action Plan.

Corrective Action Plan

This corrective action plan is in response to the city's single audit report for the fiscal year ended June 30, 2022, prepared by RAMS. Part Ill Federal Award Findings and Questioned Costs #2022-001 Recommendation: It is recommended that the City implement a tracking system to remind staff of the various reports due and respective deadlines. Corrective Action: To ensure compliance for future reporting, staff routes all contracts through DocuSign. Any grant related contract routed through DocuSign will forward a fully executed copy to the Grants Division. Grant related contracts at $30,000 or above will be flagged to inform the applicable department Management Analyst to report the contract to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Report System (FSRS) by the end of the following month. A tracking log will be maintained where applicable contracts will be listed, the deadline date to report in the FSRS, and a date to record when it was completed. This tracking log will be housed in the Grants Division folder on the City's shared drive. Person Responsible for Corrective Action: Grants Division Manager: Mary Alvarez-Gomez Department Management Analyst (various) Anticipated Completion Date for Corrective Action: It should be noted that all contracts within the audit reporting period were reported in the FFATA FSRS by 6/13/23. Corrective Action will be immediately implemented in response to the auditors' recommendation.

Categories

Subrecipient Monitoring Reporting Significant Deficiency

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.023 Emergency Rental Assistance Program $12.13M
14.218 Community Development Block Grants/entitlement Grants $3.94M
14.231 Emergency Solutions Grant Program $3.16M
16.710 Public Safety Partnership and Community Policing Grants $2.20M
14.239 Home Investment Partnerships Program $660,169
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $281,529
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $280,832
16.609 Project Safe Neighborhoods $165,061
94.016 Senior Companion Program $163,939
16.034 Coronavirus Emergency Supplemental Funding Program $130,046
84.002 Adult Education - Basic Grants to States $100,116
20.600 State and Community Highway Safety $87,100
21.016 Equitable Sharing $60,000
16.922 Equitable Sharing Program $36,887
94.002 Retired and Senior Volunteer Program $36,586
16.738 Edward Byrne Memorial Justice Assistance Grant Program $7,983
21.027 Coronavirus State and Local Fiscal Recovery Funds $1,030