Finding Text
Finding 2023-002 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency)
Information on the Federal Program:
Assistance Listing Number: 20.106
Federal Program Name: Airport Improvement Program
Federal Agency: Department of Transportation
Pass-Through Entity: N/A
Federal Award Number and Award Year: 3-06-0034-018-2020 – FY20-21
3-06-0034-021-2021 – FY21-22
Criteria:
CODE OF FEDERAL REGULATIONS, Title 49 – TRANSPORTATION, Part 18 – UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND COOPERATIVE AGREEMENTS TO STATE AND LOCAL GOVERNMENTS, Subpart C – Post-Award Requirements:
18.41 Financial Report (a) General (4), Due date. When reports are required on a quarterly or semiannual basis, they will be due 30 days after the reporting period. When required on an annual basis, they will be due 90 days after the grant year. Final reports will be due 90 days after the expiration or termination of grant support.
18.58 (a) General. The Federal agency will close out the award when it determines that all applicable administrative actions and all required work of the grant has been completed.
18.50 (b) Reports. Within 90 days after the expiration or termination of the grant, the grantee must submit all financial, performance, and other reports required as a condition of the grant. Upon request by the grantee, Federal agencies may extend this time frame. These may include but are not limited to: (1) Final performance or progress report, (2) Financial Status Report (SF 269) or Outlay Report and Request for Reimbursement for Construction Programs (SF-271) (as applicable), (3) Final request for payment (SF-270) (if applicable), and (4) Invention disclosure (if applicable).
U.S. OFFICE OF MANAGEMENT AND BUDGET CIRCULAR A-133—AUDITS OF STATES, LOCAL GOVERNMENTS, AND NON-PROFIT ORGANIZATIONS (OMB Circular A-133), Subpart C— Auditees, Section .300—Auditee Responsibilities
(b) Maintain internal control over federal programs that provides reasonable assurance that the auditee is managing federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its federal programs.
Condition and Context:
For the Airport Improvement Program (AIP), the City did not submit the reports within the required deadline:
Report Type Award Number Period Ending Date Due Date Submitted
SF-425 Financial 3-06-0034-018-2020 5/2/2022 8/2/2022 11/8/2022
SF-425 Financial 3-06-0034-021-2021 5/2/2022 8/2/2022 11/8/2022
Two (2) financial reports were tested and all reports were not submitted by the required deadline.
Cause:
Due to the effects of COVID-19 and staff turnover, the City’s procedures did not consistently ensure that the reports were submitted timely in accordance with the timelines in the Uniform Guidance, or properly reviewed and approved
prior to submission.
Effect:
Failure to submit the SF-425 financial reports timely results in noncompliance with the reporting requirements in the grant agreement.
Questioned Costs:
None noted.
Identification as a Repeat Finding, If Applicable:
Yes. See finding 2022-002.
Recommendation:
We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted timely. When a report cannot be submitted by the due date, the City
should request an extension from the funding agency and maintain a record of the approval.
Management’s View and Corrective Action Plan:
The City concurs with the auditor’s finding. The City will take steps to improve identification and monitoring of required grantor reporting deadlines.