Finding 384260 (2021-003)

Material Weakness
Requirement
C
Questioned Costs
-
Year
2021
Accepted
2024-03-25
Audit: 297401
Organization: City of Davis (CA)

AI Summary

  • Core Issue: The City is delaying drawdown requests for CDBG and HOME program expenditures, leading to a mismatch between expenses and revenues.
  • Impacted Requirements: Non-compliance with 24 CFR 570.902 due to late drawdowns, risking funding eligibility and program effectiveness.
  • Recommended Follow-Up: Establish procedures for timely drawdown submissions at least quarterly and reimburse for outstanding program expenditures promptly.

Finding Text

Finding Reference Number: SA 2021-003 Cash Management AL Number: 14.218, 14.239 Assistance Listing Title: COVID-19 - Community Development Block Grants/Entitlement Grants (CDBG) HOME Investment Partnerships Program Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-14-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037 M18-MC060237, M19-MC060237, M20-MC060237 Criteria: 24 CFR 570.902 indicates that the Department of Housing and Urban Development will review the performance of each entitlement, HUD-administered small cities, and Insular Areas recipient to determine whether each recipient is carrying out its CDBG-assisted activities in a timely manner. One of the factors in determining timeliness is the timing of the use of entitlement grant funds and the amount of undisbursed entitlement grant funds that remain in the Integrated Disbursement Information System (IDIS). Therefore, the City should submit drawdown requests in the IDIS system throughout the fiscal year as costs are incurred. Those drawdown requests should be completed at least quarterly, depending on the volume of program activity, to improve the cash management for the program and to match expenditures with associated revenues throughout the fiscal year. Although the HOME Investment Partnerships Program does not appear to have a timeliness requirement, other than 24 CFR 92.500(d) requirement to commit funds within 24 months of the grant award and the eight-year period of performance, the City should also submit drawdown requests in the IDIS system throughout the fiscal year as costs are incurred. Condition: During our testing of CDBG grant drawdown requests during fiscal year 2021, we noted that a drawdown made in April 2021 was for December 2020 expenditures, the drawdown made in May 2021 was for August 2020 expenditures, the drawdown made in June 2021 was for December 2020 expenditures and the drawdown made in September 2022 was for February 2021 to June 2021 expenditures. The City submitted the drawdown requests in the IDIS well over three months after the program expenditures were incurred. We also noted that the City did not submit drawdowns for fiscal year 2021 program expenditures we tested totaling $710. During our testing of HOME program grant drawdown requests during fiscal year 2021, we noted that two drawdowns made in June 2022 were for November 2020, January 2021, March 2021 and June 2021 expenditures, and one drawdown made in September 2022 was for March, April, May and July 2021 expenditures. Effect: The City is not matching expenditures with associated revenues throughout the fiscal year as expenditures are incurred and is at risk of being out of compliance with the provisions of 24 CFR 570.902. Cause: We understand that the drawdowns were delayed due to staff turnover. Recommendation: The City should develop procedures to ensure that drawdown requests are submitted more frequently, at least on a quarterly basis, and should requests reimbursement for the program expenditures noted above as soon as possible. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Categories

Cash Management

Other Findings in this Audit

  • 384252 2021-002
    Material Weakness
  • 384253 2021-003
    Material Weakness
  • 384254 2021-004
    Material Weakness
  • 384255 2021-005
    Material Weakness
  • 384256 2021-002
    Material Weakness
  • 384257 2021-003
    Material Weakness
  • 384258 2021-004
    Material Weakness
  • 384259 2021-005
    Material Weakness
  • 384261 2021-001
    Significant Deficiency
  • 384262 2021-001
    Significant Deficiency
  • 384263 2021-001
    Significant Deficiency
  • 384264 2021-001
    Significant Deficiency
  • 384265 2021-006
    Significant Deficiency
  • 384266 2021-006
    Significant Deficiency
  • 960694 2021-002
    Material Weakness
  • 960695 2021-003
    Material Weakness
  • 960696 2021-004
    Material Weakness
  • 960697 2021-005
    Material Weakness
  • 960698 2021-002
    Material Weakness
  • 960699 2021-003
    Material Weakness
  • 960700 2021-004
    Material Weakness
  • 960701 2021-005
    Material Weakness
  • 960702 2021-003
    Material Weakness
  • 960703 2021-001
    Significant Deficiency
  • 960704 2021-001
    Significant Deficiency
  • 960705 2021-001
    Significant Deficiency
  • 960706 2021-001
    Significant Deficiency
  • 960707 2021-006
    Significant Deficiency
  • 960708 2021-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.205 Highway Planning and Construction $2.01M
20.507 Federal Transit_formula Grants $1.15M
21.019 Coronavirus Relief Fund $854,212
14.239 Home Investment Partnerships Program $756,822
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $530,529
14.218 Community Development Block Grants/entitlement Grants $414,828
93.569 Community Services Block Grant $64,721
14.235 Supportive Housing Program $57,891
97.029 Flood Mitigation Assistance $56,766