Finding Text
Finding No. 2022-003 Federal Agency: U.S. Department of Transportation Assistance Listings Program: 20.106 Airport Improvement Program Federal Award No.: 3-66-0001-101-2017 (AIP 101) Area: Matching, Level of Effort, Earmarking Questioned Costs: $0 Criteria: In accordance with applicable matching, level of effort, earmarking requirements and with grant terms and conditions, the grantor agrees to pay ninety (90) percent of the allowable costs incurred. Condition: For 1 (or 4%) of 25 transactions, aggregating $18M of a total of $31.3M in total program expenditures, costs incurred between December 2021 and January 2022 were charged to AIP 101, which expired in September 2021. Therefore, the 90% Federal match of $525,000 should be charged to non-Federal funds. "See Schedule of Findings and Questioned Costs for chart/table" Cause: The Authority did not enforce controls over compliance with applicable matching, level of effort, earmarking requirements. Effect: The Authority is in noncompliance with applicable matching, level of effort, earmarking requirements. No questioned cost is presented because the Authority effected corrective action, as described below. Subsequently, during April 2023 through June 2023, the Authority corresponded with, and received guidance from, U.S. Department of Transportation, Federal Aviation Administration (FAA), relative to corrective action. The Assistant Manager, FAA Honolulu Airports District Office, stated in an email dated 05/24/2023,?Grant-105 hasn?t been closed out yet,? and in an email dated 06/03/2023, ?Can?invoice on project costs incurred after Grant-101?s POP End Date be paid under Grant 105? Both grants are for the same project.? On June 23, 2023, the Authority provided sufficient documentation to demonstrate that the invoice total and Federal expenditures above now represent allowable costs incurred prior to the grant?s expiration date. Finding No. 2022-003, continued Federal Agency: U.S. Department of Transportation Assistance Listings Program: 20.106 Airport Improvement Program Federal Award No.: 3-66-0001-101-2017 (AIP 101) Area: Matching, Level of Effort, Earmarking Questioned Costs: $0 Recommendation: Responsible personnel should enforce controls over compliance with applicable matching, level of effort, earmarking requirements and with grant terms and conditions. Prior to identifying the grantor?s match for Federal draws, the responsible personnel should verify that underlying expenditures are allowable costs that were incurred prior to the expiration of the Federal award. Views of Responsible Officials: This finding is a result of a grant amendment having only covered a change in the grant amount and not the period of performance. The Authority had requested for an amendment to AIP 101 on December 15, 2020?nine months prior to the period of performance (POP) expiration. The amendment was issued by the Federal Aviation Administration (FAA) on January 4, 2022?over three months after the POP expiration. Upon clarification with the FAA, the Authority took corrective measures to address the miscommunication on the agreement extension and has settled the issue. The Authority will ensure it reviews the terms of grant amendments for critical information, such as changes to POP dates, to reinforce its current controls over compliance with applicable matching, level of effort, and earmarking requirements to prevent similar findings in the future.