Finding Text
Federal Grantor: U.S. Department of Treasury
Pass-through Grantor: n/a
Federal Assistance Listing No.: 21.027
Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Award Year: 2022
Compliance Requirement: Reporting
Known Questioned Costs: n/a Criteria: Title 2 U.S. Code of Federal Regulations Part 200 requires recipients of Federal awards to comply with laws, regulations, and provisions of contract or grant agreements related to each of its Federal programs. Participants in the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program were required to complete financial, performance, and compliance reporting as outlined in Part 2 of the SLFRF Compliance and Reporting Guide, issued by the U.S. Department of the Treasury. The County was required to appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. Condition: The County elected to obligate the entire COVID-19 Coronavirus State and Local Fiscal Recovery Funds grant award of $6,951,594 for the provision of government services in accordance with the $10 million standard allowance exemption as outlined in the 2022 Final Rule guidance; the standard allowance provision allows a recipient to reimburse itself for eligible past expenditures incurred on or after March 3, 2021 through the date of the standard allowance election. A reimbursement is a transaction in the fiscal year in which the Commission authorized the reimbursement. For reporting purposes, the COVID-19 Coronavirus State and Local Fiscal Recovery Funds are considered obligated and expended on the date that the Commission authorized the reimbursement of the specific prior expenditure(s). Accordingly, the County elected to reimburse $804,077 of salaries and wages incurred between the period of March 3, 2021 and March 7, 2022 for which a transfer of cash between the COVID-19 Fund and the Emergency Reserve Fund was executed on March 7, 2022. This expenditure was not included in the total expenditures reported in the Project and Expenditure Report due on April 30, 2022. Cause: Oversight. Effect: The Project and Expenditure Report due by April 30, 2022, which covered the period of March 3, 2021 - March 31, 2022, was submitted with inaccurate expenditures. Total expenditures reported under the County's revenue replacement category for the covered period totaled $26,646, however, the County's underlying accounting records supported total expenditures for the covered period of $818,089. Recommendation: We recommend that the County implement internal controls to ensure that the Project and Expenditure reports completely and accurately state the cumulative expenditures and current period expenditures of funds expended under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds including performing a reconciliation between the reporting to be submitted and the underlying accounting records. Additionally, the County should include the omitted expenditures in the next Project and Expenditure Report submission using the procedures reflected in the U.S. Department of Treasury Project and Expenditure Report Guide, as applicable to the covered period being submitted. Management's Response: The clerk is preparing and reporting COVID-19 funds and will work with the supervisor and treasurer to ensure correct reporting in the future. To be implemented in the next reporting cycle April 2024.