Finding 400374 (2023-001)

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Requirement
L
Questioned Costs
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Year
2023
Accepted
2024-06-07
Audit: 308412
Organization: City of Hayward (CA)

AI Summary

  • Core Issue: The City failed to report first-tier subawards of $30,000 or more in the FSRS for fiscal year 2023.
  • Impacted Requirements: This non-compliance violates the FFATA reporting requirements, which mandate timely and accurate reporting of subawards.
  • Recommended Follow-Up: The City should establish clear procedures to ensure compliance with FFATA reporting requirements moving forward.

Finding Text

Finding Reference Number: SA 2023-001 Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants/Entitlement Grants (CDBG) Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number and Year: B-23-MC-06-0012 (2023) Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 that are codified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subawards that are entered into the FSRS System should be maintained so that any amendments to the subawards are also reflected in the system. Condition: We noted that the City had not reported first-tier subawards of $30,000 or more in the FSRS during fiscal year 2023. Effect: The City is not in compliance with the FFATA reporting requirements. Cause: We understand that program staff were not familiar with the FFATA reporting requirements. Recommendation: We recommend that the City develop procedures to ensure that all reporting requirements for programs subject to the Federal Funding Accounting and Transparency Act are adhered to. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

• Finding Reference Number: SA 2023-001 Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants/Entitlement Grants (CDBG) Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number and Year: B-23-MC-06-0012 (2023) Name of pass-through Entity: None Name(s) of the contact person: Christina Crosby Corrective Action Plan: Beginning with the current FY25 Community Agency Funding Process, the Community Services Division (CSD) will integrate Federal Funding Accountability and Transparency Act (FFATA) compliance into its existing contracting processes. Language regarding grantees’ reporting responsibilities has been added to the CDBG Public Services, Economic Development, and Infrastructure Contract templates, including the need to register with the System for Award Management (SAM) and provide executive compensation information. A description of FFATA responsibilities has also been integrated into award communications. Community Services Division is currently preparing to provide grantees with SAM.gov registration support as part of our overall contract process technical assistance. CSD staff is also in the process of registering for both SAM.gov to access grantee submissions as well as Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). FSRS is the federal portal where staff will provide grantee executive compensation and demographic information as required by FFATA. FFATA compliance processes, both information gathering and reporting to FSRS, have been added to staff’s internal timelines and checklists to ensure that reporting will be in compliance within the 30 days of contract execution required by law. This will form the basis for the Community Agency Funding processes in future years. In addition, the Finance department will review all grant awards over $30,000 with other City divisions to verify and ensure compliance with FFATA reporting requirements continue to be met. • Anticipated Completion Date: Complete

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $1.30M
14.239 Home Investment Partnerships Program $597,428
84.215 Fund for the Improvement of Education $339,757
20.106 Airport Improvement Program $285,585
93.778 Medical Assistance Program $250,868
97.039 Hazard Mitigation Grant $95,760
16.738 Edward Byrne Memorial Justice Assistance Grant Program $38,877
20.600 State and Community Highway Safety $30,977
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $25,399
21.027 Coronavirus State and Local Fiscal Recovery Funds $5,838
97.067 Homeland Security Grant Program $1,477