Finding 38150 (2022-001)

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Requirement
M
Questioned Costs
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Year
2022
Accepted
2022-12-20
Audit: 29988
Organization: City of Franklin, Tennessee (TN)
Auditor: Crosslin PLLC

AI Summary

  • Core Issue: The Franklin Transit Authority failed to properly report and monitor subrecipients, leading to noncompliance with federal requirements.
  • Impacted Requirements: Issues included misclassifying contractors as subrecipients, inadequate internal controls over payroll expenditures, and improper reporting under the FFATA.
  • Recommended Follow-Up: The City should continue implementing its corrective action plan to enhance monitoring and compliance for the Federal Transit program.

Finding Text

ITEM #2022-001 FRANKLIN TRANSIT AUTHORITY PROGRAM REVIEW Federal Transit Cluster Assistance Listing No. 20.507, 20.500 U.S. Department of Transportation Criteria The Federal Transit Cluster requires the City (specifically the Franklin Transit Authority as recipient of the grants) to properly report and monitor subrecipients, maintain internal controls over expenditures charged to the program, and properly report awards and subawards in the Federal registry in accordance with the Federal Funding Accountability and Transparency Act (FFATA). Condition and Context The Federal Transit Authority conducted a Full Scope Systems Review of the Franklin Transit Authority (a special revenue fund of the City) in fiscal year 2021 and issued their final report in April 2022. In their report, instances of noncompliance were noted over the Federal Transit Cluster, including: ? Reporting and monitoring of subrecipients: the City improperly reported the TMA Group as a subrecipient in the Schedule of Expenditures of Federal Awards (SEFA). The TMA Group is a contracted management company hired by the City to manage the Franklin Transit Authority. The TMA Group meets the criteria of a contractor, and therefore should not have been reported as a subrecipient in the City?s SEFA. The City also did not report Williamson County as a subrecipient of portions of the grant program in the City?s SEFA, and was not properly monitoring Williamson County as a subrecipient. ? Maintain internal controls over expenditures charged to the program: the City has documented and implemented internal controls over federal expenditures, however it was noted the City did not document approvals on all of the payroll registers containing salaries charged to the Federal Transit program. ? Reporting awards and subawards in the Federal registry in accordance with the FFATA: it appeared the City was not reporting awards and subawards in accordance with FFATA for the Federal Transit program. Questioned Cost None Cause The City did not have proper controls in place over the grant program to ensure compliance with certain requirements noted above. Effect The City was not in compliance with certain requirements of the Federal Transit Cluster. Recommendation The City has developed and began implementation of a plan to better monitor internal controls and compliance requirements over the daily functions of the Franklin Transit Authority and the Federal Transit program. We recommend the City continue to follow and fully implement their plan. Views of Responsible Officials and Planned Corrective Action City officials have corrected deficiencies in the report through the following corrective action plan.

Corrective Action Plan

The City of Franklin respectfully submits the following corrective action plan for the year ended June 30, 2022. Contact Person/Persons Responsible for Implementing Corrective Action: Eric Stuckey, City Administrator, 615-791-3217 2022-001: Franklin Transit Authority Program Review Action Taken/Planned: As recommended, the City of Franklin and the Authority have clarified the federal grant organization as follows: For transit services, the organization is as follows: (1) Recipient: Franklin Transit Authority (2) Contractor (current): The TMA Group For the regional vanpool program, the organization is as follows: (1) Recipient: Franklin Transit Authority (2) Sub-Recipient: Regional Transportation/Williamson County (3) Contractor (current): The TMA Group The Authority has previously and will continue to be reported as part of the City of Franklin in a special revenue fund and includes the Authority?s grants in its single audit. For the fiscal year 2022 audit, the City and the Contractor have coordinated to ensure federal grants for transit services and vanpool services are excluded from the Contractor audit. For fiscal year 2023, the City and the Contractor developed backup needed for oversight of each payment to the Contractor for contracted transit services and grant-related contracted vanpool services. Monthly reporting will clarify financial activities of the recipient (Franklin Transit), subrecipient (Regional Transportation Authority/Williamson County), and contractor (The TMA Group). For capital expenditures that the City and the Authority have ownership, the City will continue to pay the vendor directly. The City of Franklin and the Authority have developed a job description, issued a job posting, and conducted interviews for a part-time Contract Compliance Monitor. The position, the Authority?s only employee, will monitor the activities of the Contractor (currently The TMA Group) and the subrecipient (Williamson County) to ensure that the awards are used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the contract or subaward. Based on the amount and level of work required, the position is under direction of the Authority. The monitor essentially functions in a control/compliance role. The position is anticipated to be paid through the City?s payroll process from the Authority fund. Anticipated Completion Date/Date Completed: January 2023

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
66.458 Capitalization Grants for Clean Water State Revolving Funds $9.77M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.54M
14.218 Community Development Block Grants/entitlement Grants $184,369
20.205 Highway Planning and Construction $113,560
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $28,103
20.507 Federal Transit_formula Grants $25,059
20.600 State and Community Highway Safety $23,127
16.607 Bulletproof Vest Partnership Program $10,955
15.904 Historic Preservation Fund Grants-in-Aid $5,000