Finding 33001 (2022-023)

- Repeat Finding
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-05-04

AI Summary

  • Core Issue: The City lacks timely procedures for monitoring subrecipients, leading to unaddressed deficiencies in compliance.
  • Impacted Requirements: Subrecipients may improperly receive federal funds, risking undetected questioned costs due to insufficient follow-up on compliance issues.
  • Recommended Follow-Up: Develop a formal subrecipient monitoring policy with clear procedures, timing, and follow-up actions to ensure compliance and address deficiencies promptly.

Finding Text

U.S. DEPARTMENT OF TREASURY: 2022-023 Compliance with Subrecipient Monitoring Fiscal year finding initially occurred: 2021 Emergency Rental Assistance Program (21.023) Criteria An effective system of internal controls contemplates that management properly review and assess the subrecipient through monitoring procedures and documents the results of the procedures performed. This includes ensuring the subrecipient is following all direct and material compliance requirements applicable to each federal program. Condition During the current fiscal year, the Government performed one monitoring visit to each of the subrecipients. In this visit they tested 48 case files and reviewed them for compliance with record keeping and eligibility requirements. They identified 2 deficiencies in one of the subrecipients? case files. Which were corrected before they completed their visit. The other subrecipient had three deficiencies that were not corrected before the visit was completed. In addition, there was no follow-up by management on these deficiencies and as of 4/14/23, they have not performed a subsequent site visit. Cause The City does not have sufficient procedures in place to perform subrecipient monitoring in a timely manner and to follow-up on identified deficiencies. Effect The subrecipient could provide federal funds to ineligible individuals resulting in questioned costs that could go undetected. Recommendation We recommend the Government develop a formal policy in relation to subrecipient monitoring including the review procedures to be performed, the timing, frequency of the monitoring(s) and follow-up procedures. The Government should formally document their risk assessment of the subrecipient to support the nature, timing, and extent of testing of the subrecipient. Views of Responsible Officials and Planned Corrective Action The Government originally received this finding in 2021 to which the response was it would monitor subrecipients no less than once per fiscal year in which the awardee received funding or otherwise as required by Federal regulation for individual grants. The Government has met that requirement. In order to further improve upon monitoring practices, the Government will perform follow-up monitoring reviews within 3 months, as applicable by program type, of finding deficiencies in the subrecipients? programs to ensure corrective active has taken place. The Government will also consider the subaward amount as part of the risk assessment when contracting with each subrecipient; higher risk subrecipient programs will be monitored at a more frequent interval. This project is expected to be completed within six months and will be overseen by the Community Development & Planning Director Mary Sliman.

Corrective Action Plan

U.S. DEPARTMENT OF TREASURY: Emergency Rental Assistance Program (21.023) 2022-023 Compliance with Subrecipient Monitoring Recommendation: We recommend the Government develop a formal policy in relation to subrecipient monitoring including the review procedures to be performed, the timing, frequency of the monitoring(s) and follow-up procedures. The Government should formally document their risk assessment of the subrecipient to support the nature, timing, and extent of testing of the subrecipient. Corrective Action Plan: The Government originally received this finding in 2021 to which the response was it would monitor subrecipients no less than once per fiscal year in which the awardee received funding or otherwise as required by Federal regulation for individual grants. The Government has met that requirement. In order to further improve upon monitoring practices, the Government will perform follow-up monitoring reviews within 3 months, as applicable by program type, of finding deficiencies in the subrecipients? programs to ensure corrective active has taken place. The Government will also consider the subaward amount as part of the risk assessment when contracting with each subrecipient; higher risk subrecipient programs will be monitored at a more frequent interval. This project is expected to be completed within six months and will be overseen by the Community Development & Planning Director Mary Sliman.

Categories

Subrecipient Monitoring Eligibility

Other Findings in this Audit

  • 32983 2022-021
    - Repeat
  • 32984 2022-026
    Material Weakness Repeat
  • 32985 2022-021
    - Repeat
  • 32986 2022-026
    Material Weakness Repeat
  • 32987 2022-021
    - Repeat
  • 32988 2022-026
    Material Weakness Repeat
  • 32989 2022-020
    - Repeat
  • 32990 2022-021
    - Repeat
  • 32991 2022-025
    Significant Deficiency Repeat
  • 32992 2022-026
    Material Weakness Repeat
  • 32993 2022-021
    - Repeat
  • 32994 2022-026
    Material Weakness Repeat
  • 32995 2022-021
    - Repeat
  • 32996 2022-026
    Material Weakness Repeat
  • 32997 2022-021
    - Repeat
  • 32998 2022-022
    -
  • 32999 2022-026
    Material Weakness Repeat
  • 33000 2022-027
    Material Weakness
  • 33002 2022-028
    Material Weakness
  • 33003 2022-024
    -
  • 33004 2022-029
    Material Weakness
  • 609425 2022-021
    - Repeat
  • 609426 2022-026
    Material Weakness Repeat
  • 609427 2022-021
    - Repeat
  • 609428 2022-026
    Material Weakness Repeat
  • 609429 2022-021
    - Repeat
  • 609430 2022-026
    Material Weakness Repeat
  • 609431 2022-020
    - Repeat
  • 609432 2022-021
    - Repeat
  • 609433 2022-025
    Significant Deficiency Repeat
  • 609434 2022-026
    Material Weakness Repeat
  • 609435 2022-021
    - Repeat
  • 609436 2022-026
    Material Weakness Repeat
  • 609437 2022-021
    - Repeat
  • 609438 2022-026
    Material Weakness Repeat
  • 609439 2022-021
    - Repeat
  • 609440 2022-022
    -
  • 609441 2022-026
    Material Weakness Repeat
  • 609442 2022-027
    Material Weakness
  • 609443 2022-023
    - Repeat
  • 609444 2022-028
    Material Weakness
  • 609445 2022-024
    -
  • 609446 2022-029
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.023 Emergency Rental Assistance Program $11.98M
21.027 Coronavirus State and Local Fiscal Recovery Funds $3.29M
97.029 Flood Mitigation Assistance $985,623
11.307 Economic Adjustment Assistance $711,283
14.218 Community Development Block Grants/entitlement Grants $671,489
59.075 Shuttered Venue Operators Grant Program $557,070
20.507 Federal Transit_formula Grants $527,315
20.527 Public Transportation Emergency Relief Program $350,000
10.927 Emergency Watershed Protection Program - Disaster Relief Appropriations Act $305,261
20.500 Federal Transit_capital Investment Grants $228,751
16.609 Project Safe Neighborhoods $94,765
16.710 Public Safety Partnership and Community Policing Grants $78,912
14.239 Home Investment Partnerships Program $69,445
20.219 Recreational Trails Program $32,488
20.600 State and Community Highway Safety $32,271
45.312 National Leadership Grants $28,121
16.034 Coronavirus Emergency Supplemental Funding Program $20,900
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $17,922
15.916 Outdoor Recreation_acquisition, Development and Planning $15,356
20.205 Highway Planning and Construction $12,625
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $4,602
97.039 Hazard Mitigation Grant $3,725
16.751 Edward Byrne Memorial Competitive Grant Program $3,176
16.588 Violence Against Women Formula Grants $2,007
16.738 Edward Byrne Memorial Justice Assistance Grant Program $1,107