Finding 478374 (2023-004)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2023
Accepted
2024-07-12
Audit: 315062
Organization: City of Santa Fe (NM)

AI Summary

  • Core Issue: Duplicate pay periods were included in reimbursement requests, leading to inaccuracies in the general ledger.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303(a) and 2 CFR 200.430(f) regarding internal controls and allowable costs.
  • Recommended Follow-Up: Strengthen internal controls to prevent duplicate entries and ensure accurate reporting for federal awards.

Finding Text

2023‐004 – Activities Allowed, Allowable Costs over Payroll (Material Noncompliance, Material Weakness over Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF‐SWG‐3‐35‐0037‐057‐2021 Federal Award Year: 2023 Condition: During reconciliation of the general ledger to the SEFA, it was noted multiple pay periods were duplicated which were included in request for reimbursement. Criteria: Per 2 CFR 200.303(a), the non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.430(f) – Factors affecting allowability of costs ‐ Not be included as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on the general ledger as charged to the grant. Questioned Cost: Known and likely questioned costs of $86,333 Effect: The City requested reimbursement for duplicate transactions resulting in disallowed costs.

Corrective Action Plan

Recommendation: The auditor recommends the City strengthen policies and procedures to ensure a review of the general ledger for the federal program to ensure no duplicate costs are charged prior to reimbursement. Additionally, the Finance Department should provide secondary review on all requests for reimbursements. Action Taken: The City agrees with this finding. When this issue was brought to the attention of the Finance Director and Accounting Officer as material noncompliance, the schedule of expenditures of federal awards (SEFA) was revised to remove the duplicated expenditures. Management proposed an adjusting journal entry prior to the completion of the audit to record the amount of the reimbursement for duplicated expenditures as a liability “due to Federal Government”. The City will work with the awarding agencies to return the funds that were reimbursed incorrectly. When this reimbursement request was done the payroll expenditure data that was used to calculate the reimbursement request was compiled manually by combining multiple reports. This was a manual process. The process has changed, so that now the Airport Administrative Manager gets one report directly from the Payroll Division that contains all Airport payroll expenditure data. In November 2022 (about 5 months into FY23) the City hired a new Airport Manager with substantial experience managing municipal airports and overseeing federal funding for airports. In CY24 the Finance Director and the Accounting Officer will work with the Airport staff to strengthen policies and procedures to ensure a review of the general ledger for the federal program to ensure no duplicate costs are charged prior to reimbursement. Secondary review by the Finance Department or a vendor approved by the Finance Director will be required for all Airport requests for reimbursements. The City is in the process of identifying a vendor to contract with Airport to assist with federal compliance and provide training to Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will include performing secondary review of requests for reimbursement and helping with developing and documenting policies and standard opera􀆟ng procedures for requests for reimbursement. In CY24 the City will provide Uniform Guidance training to staff which will include internal controls related to activities allowed and allowable costs over payroll. Due Date of Completion: December 31, 2024 Responsible Official: Emily Oster - Finance Director, James Harries - Airport Manager, Matthew Bonifer - Accounting Officer, Grants Manager (in recruitment).

Categories

Questioned Costs Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 478375 2023-005
    Material Weakness
  • 478376 2023-006
    Material Weakness
  • 478377 2023-007
    Material Weakness Repeat
  • 478378 2023-004
    Material Weakness
  • 478379 2023-005
    Material Weakness
  • 478380 2023-006
    Material Weakness
  • 478381 2023-007
    Material Weakness Repeat
  • 478382 2023-004
    Material Weakness
  • 478383 2023-005
    Material Weakness
  • 478384 2023-006
    Material Weakness
  • 478385 2023-007
    Material Weakness Repeat
  • 478386 2023-004
    Material Weakness
  • 478387 2023-005
    Material Weakness
  • 478388 2023-006
    Material Weakness
  • 478389 2023-007
    Material Weakness Repeat
  • 1054816 2023-004
    Material Weakness
  • 1054817 2023-005
    Material Weakness
  • 1054818 2023-006
    Material Weakness
  • 1054819 2023-007
    Material Weakness Repeat
  • 1054820 2023-004
    Material Weakness
  • 1054821 2023-005
    Material Weakness
  • 1054822 2023-006
    Material Weakness
  • 1054823 2023-007
    Material Weakness Repeat
  • 1054824 2023-004
    Material Weakness
  • 1054825 2023-005
    Material Weakness
  • 1054826 2023-006
    Material Weakness
  • 1054827 2023-007
    Material Weakness Repeat
  • 1054828 2023-004
    Material Weakness
  • 1054829 2023-005
    Material Weakness
  • 1054830 2023-006
    Material Weakness
  • 1054831 2023-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19: Coronavirus State and Local Fiscal Recovery Funds $3.12M
14.218 Community Development Block Grants/entitlement Grants $1.32M
20.106 Airport Improvement Program #54 $850,534
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $348,239
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $273,667
97.067 Homeland Security Grant Program $239,056
20.106 Airport Improvement Program #51 $234,351
14.218 Covid-19: Community Development Block Grants/entitlement Grants $223,455
20.205 Highway Planning and Construction $147,490
93.053 Nutrition Services Incentive Program $109,484
93.045 Special Programs for the Aging_title Iii, Part C-1_nutrition Services $94,043
93.788 Opioid Str $84,307
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $48,568
93.045 Special Programs for the Aging_title Iii, Part C-2_nutrition Services $43,840
20.106 Airport Improvement Program #52 $42,035
94.002 Retired and Senior Volunteer Program $40,861
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $35,431
94.011 Foster Grandparent Program $34,773
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $32,059
93.052 National Family Caregiver Support, Title Iii, Part E $29,101
20.106 Airport Improvement Program #53 $27,360
45.024 Promotion of the Arts_grants to Organizations and Individuals $15,000
93.052 Covid-19: National Family Caregiver Support, Title Iii, Part E Arpa $14,972
97.042 Emergency Management Performance Grants $3,249