Finding 393862 (2023-001)

Information on the federal program: U.S. Department of the Treasury, Assistance listing # 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Criteria: 2 CFR 200.328-300 establish requirements for designing and monitoring internal controls over reporting requirements of a non-federal entity. Controls should be implemented to ensure accurate and complete reporting compliance. The Coronavirus State and Local Fiscal Recovery Funds: Overview of the Final Rule establishes the specific requirements for ARPA fund reporting. Condition: We examined the annual Project and Expenditure report required. It was not filed within 30 days of specified year end as required. Cause: There had been no fund expenditures prior to December of 2022. Annual reporting requirements for ARPA funds is at March 30 year end. The City’s controls around reporting focus on fiscal quarter end and fiscal and calendar year end. This reporting period is not in the City’s normal reporting schedule and therefore was not addressed through the controls in place. Effect: The City did not timely fulfill the related reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures surrounding grant reporting to include (at inception of each award) documentation of a schedule of reporting requirements, review, and approvals to ensure documentation is retained to support compliance requirements. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan included at the end of the report.