Finding 406005 (2023-001)

Special Tests and Provisions Federal Department – U.S. Department of Housing and Urban Development Federal Award Identification Number and Year: E-20-UW-17-0001 and 2020 E-22-UC-17-0001 and 2022 Emergency Solutions Grant Program, Federal Assistance Listing #14.231 County Department – Department of Planning and Development Finding 2023 – 001 CRITERIA 24 CFR Part 576, Emergency Solutions Grants Program, Subpart C - Award and Use of Funds, Section 576.203 Obligations, expenditure, and payments requirements (c) Payments to Subrecipients states, “The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s complete payment request. This requirement also applies to each subrecipient that is a unit of generalpurpose local government.” CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not adequately comply with its special tests and provisions requirements in accordance with federal regulations. CAUSE Based on discussions with management, this finding occurred due to the DPD receiving invoices from subrecipients that had missing support documentation or included incorrect support documentation. The DPD has hired new staff that will assist with training subrecipients on submission of invoices. EFFECT The failure to pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s complete payment request is a violation of federal regulations. This could impact the subrecipient’s ability to adequately perform its programmatic responsibilities under the program. QUESTIONED COSTS None. CONTEXT During the prior audit period, we noted four instances (of 44 subrecipients’ expenditures) where payments to the subrecipients were not made within 30 days after receiving the subrecipient’s complete payment request, as required. This resulted in the 2022 audit finding and subsequent corrective action planned prepared by DPD to address the finding, which included corrective action planning to be implemented on future grants as this grant will close in September 2023. During the current audit period, we received DPD’s current year status of the prior audit finding, noting that the corrective action plan discussed and implemented did not address the issues which were noted in the 2022 audit finding. Furthermore, we tested 40 subrecipients’ expenditures, noted four instances where payments to the subrecipients were not made within 30 days after receiving the subrecipient’s complete payment request, as required. The payments were submitted late, ranging from 13 to 74 days late. Also, we noted that for two of these subrecipients’ expenditures the payment request occurred after September 2023. IDENTIFICATION OF REPEATED FINDINGS Repeated (Prior Finding No. 2022-002) RECOMMENDATION We recommend that DPD develop and implement procedures to ensure payments to subrecipients are made within 30 days after receipt of the subrecipients complete payment request, as required. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 53.