Finding 42200 (2022-001)

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Requirement
LP
Questioned Costs
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Year
2022
Accepted
2023-03-28
Audit: 38929
Organization: City of Santa Clara (CA)

AI Summary

  • Core Issue: The City missed key deadlines for reporting and fund management related to three CAPP grants.
  • Impacted Requirements: Late filing of reports and delayed allocation of funds violate grant conditions, risking potential repayment to grantors.
  • Recommended Follow-Up: The City should establish procedures to ensure timely compliance with grant terms, including reporting and fund usage.

Finding Text

Finding Reference Number: SA2022-001 Compliance with Grant Deadlines Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Federal Award Identification Number: SLFRP0002 68-0283471 68-0281986 Name of Pass-Through Entity: State of California Department of Community Services California State Water Resources Control Board Criteria: The City?s three California Arrearage Payment Program (CAPP) grants included a number of deadlines for transaction processing, reporting and return of unused funds as follows: ? Electric Utility Arrearage CAPP Program Notice No. 2022-01 requires the filing of the Close-Out Report within six months of receipt of the grant funds, or August 7, 2022. ? California Water and Wastewater Arrearage Payment Program Guidelines Section B requires that the City allocate Water Arrearage Program payments as bill credits to customer accounts within 60 days of receiving payment or March 26, 2022. ? California Water and Wastewater Arrearage Payment Program Guidelines Appendix A, Section 6.3, requires the return of unspent Wastewater Arrearage Program funds within six months of receiving payment or November 30, 2022 Condition: The City did not comply with the required reporting and other program deadlines above as follows: ? Electric Utility Arrearage Close-Out Report was not filed until August 30, 2022. ? Water Utility Arrearage Program bill credits were not applied to customer accounts until April 4, 2022. ? Wastewater unused funds were not returned to the State Water Resources Control Board until January 6, 2023. Cause: We understand that staff shortages as well as the complexities of calculating the customer credits led to the reporting, deposit, credit and payment delays. Effect: The City is not in compliance with the terms and conditions of payment related to the required reporting and other program deadlines of the California Arrearage Payment Programs. As a result, the City could have been required to return moneys to the grantors. Recommendation: Although it does not appear that the grantors disallowed any of the program costs, the City must develop procedures to ensure compliance with grant award terms and conditions of payment, including timely filing of reports, timely use of grant funds and timely return of unspent grant funds. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

Finding Reference Number: SA2022-001 Compliance with Grant Deadlines Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Federal Award ID Number: COVID-19 ? SLFRP0002 COVID-19 ? 68-0283471 COVID-19 ? 68-0281986 Name of Pass-Through Entity: State of California Department of Community Services California State Water Resources Control Board Name(s) of the contact person: Gary Welling, Director of Water & Sewer Utilities Water and Sewer Manuel Pineda, Chief Electric Utility Officer Fiscal Year of Initial Finding: 2021-2022 Corrective Action Plan: The City has taken action and corrected the issues related with this finding. The City has also taken steps to improve business processes to prevent this issue from occurring again. Staff are required to develop a checklist to manage the reporting and compliance requirements for the grant that they manage to ensure that the City meets the grant?s reporting requirements. Anticipated Completion Date: March 23, 2023

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $1.14M
14.218 Community Development Block Grants/entitlement Grants $956,936
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $806,167
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $618,613
16.734 Special Data Collections and Statistical Studies $200,089
16.922 Equitable Sharing Program $61,727
16.738 Edward Byrne Memorial Justice Assistance Grant Program $40,791
97.044 Covid-19 - Assistance to Firefighters Grant $32,745
20.205 Highway Planning and Construction $27,791
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $25,248
97.042 Emergency Management Performance Grants $22,414
97.025 National Urban Search and Rescue (us&r) Response System $16,013
20.600 State and Community Highway Safety $12,313
16.034 Covid-19 - Coronavirus Emergency Supplemental Funding Program $9,967
97.067 Homeland Security Grant Program $8,031