Finding 392483 (2022-004)

Finding 2022–004: Reporting Federal Department: U.S. Department of Treasury Pass-through Agencies: Cook County, Illinois and Women's Business Development Center COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, Federal Assistance Listing Number 21.027 Criteria The Subrecipient Agreement for American Rescue Plan Act- State and Local Fiscal Recovery Funds between Cook County, Illinois (the County) and SDA, Exhibit A – Scope of Work states SDA shall provide performance and financial metrics and reports to the County on a monthly basis or as determined by the County and outlined in reporting and metrics sections of this agreement. Per the agreement, invoice (expense) submission is due at the end of each month and/or if funds are received in advance, the submission is due within one month of the expenditure. In addition, monthly performance (impact metrics) reporting of data will take place on the 15th day of each month following the reporting period in which it is applicable. The following program metrics will be collected and provided to the County in the following categories: 1) Client Service Metrics; 2) Develop annual survey to capture Business Growth Metrics; 3) Develop annual survey to capture Capital Metrics; 4) Marketing and Outreach Metrics; and 4) Financial Reporting. The 2022 Amendment to the Subaward and Fund Distribution Memorandum of Understanding (MOU) agreement dated December 15, 2021 between the Women’s Business Development Center (WBDC) and SDA states a provider seeking expense reimbursement shall provide supporting documentation at the end of each month with WBDC or Next Street for each expense item. The second amendment to the MOU covering the period beginning April 1, 2022 to November 30, 2026, states that invoice shall be submitted for review by August 12 for April through June expenses, October 14 for July through September expenses, and December 9 for October through November expenses. Condition During the current audit period, SDA did not comply with the reporting requirements outlined in its grant agreements. Cause Based on our discussions with management, this finding occurred due to staff turnovers and management’s oversight as proper reminders were not set up at commencement of the grant agreement(s). Effect Failure to submit reports in a timely manner impairs the grantor agency’s ability to monitor program activities and could result in the loss of grant funding. Also, the failure to maintain adequate supporting documentation could result in inaccurate reporting and is a violation of grantor(s) reporting requirements. Questioned Costs None. Context During our test of monthly and quarterly reports submitted under the program, we reviewed a total of eight reports (six monthly reports from the two County grant agreements and two quarterly reports from the WBDC grant agreement). We noted that seven reports were submitted late, ranging from six to 195 days late. Also, for five of the six County grant reports above, we were unable to obtain evidence to support the completion and submission of the performance reporting metrics. Based on our current year walkthrough and discussions with SDA management, we noted that SDA utilized the Salesforce system to track, report and submit information related to these performance metrics. However, a copy of the Data Collection Form after submission was not maintained on file. Identification of Repeated Findings Repeated (Prior Finding No. 2020-003, 2021-003). Recommendation We recommend that SDA implement procedures to ensure required reports are prepared, reviewed and submitted in a timely manner and in compliance with its grant agreements. Additionally, adequate documentation should be appropriately maintained to support all reports prepared and submitted under the grant agreements. Views of Responsible Officials and Planned Corrective Action SDA agrees with the finding and recommendation. See SDA’s Corrective Action Plan on pages 40–44.