Finding 478998 (2023-001)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-07-19
Audit: 315527
Organization: Arapahoe County, Colorado (CO)

AI Summary

  • Core Issue: The County failed to submit required FFATA reports on time, impacting compliance with federal reporting standards.
  • Impacted Requirements: 2 CFR 200.303 and 2 CFR Part 170, which mandate proper internal controls and timely reporting of subawards.
  • Recommended Follow-Up: Continue improving processes in fiscal year 2024 to ensure timely submission and tracking of FFATA reports.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Development Block Grant and COVID-19 Community Development Block Grant Assistance Listing Number: 14.218 Award Period: January 1, 2023 through December 31, 2023 Award Number: B-18-UC-08-0002, B-19-UC-08-0002, B-20-UC-08-0002, B-20-UW-08-0002, B-21-UC- 08-0002, B-22-UC-08-0002, and B-23-UC-08-0002 Compliance Requirement: Reporting - Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: 2 CFR 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) reports, it was noted that no FFATA reporting had been completed during the year ended December 31, 2023. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 6 6 6 Not tested Not tested Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $ 480,000 $ 480,000 $ 480,000 Not tested Not tested Questioned costs: None. Context: While the reports were not filed timely, the supporting documentation that was needed to file the report was gathered by the County and the filing was completed in May 2024. Cause: The County experienced turnover during the fiscal year which impacted the timeliness of the submissions. Effect: Compliance with the reporting requirement for this program is not being met and the information is not being provided on the public website. Repeat Finding: No Recommendation: We recommend that the County continue with the process being implemented during the fiscal year 2024, which includes completing submission of the reports and tracking the timely submission of the FFATA reports. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Community Development Block Grant and COVID-19 Community Development Block Grant – Material Weakness Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) reports, it was noted that no FFATA reporting had been completed during the year ended December 31, 2023. Recommendation: We recommend that the County continue with the process being implemented during the fiscal year 2024, which includes completing submission of the reports and tracking the timely submission of the FFATA reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With significant turnover of tenured leadership and employees within the Community Resources Department, Arapahoe County Community Resources took proactive measures in 2023 for review of the Community Development Housing and Homeless Services (CDHHS) programs (CDBG and HOME Investment) by recognized consultants within the field. Community Resources has contracted with two consultants, to assist in a full review and re-development of policies and procedures (Civitas) for the CDBG and HOME programs as well as a full review of all case files (Affordable Housing Consultants). Included with this response are the contracts with both Civitas and Affordable Housing Consultants for verification purposes. The County anticipates their work to be completed and an implementation of updated policies and procedures for these programs by fall of 2024. In response to the direct finding of no FFATA reporting during the year ending December 31st, 2023, Arapahoe County has ensured the entry of all sampled contracts. Demonstration of the report submissions have been submitted for verification purposes. It is important to note that all sub-agreements included the necessary FFATA information for the review period, but Community Resources failed to ensure that this information was entered into the FFATA Subaward Reporting System (FSRS). To ensure internal controls are in place for the FFATA’s timely and accurate submissions for all future subawards, Arapahoe County’s Community Resources Department has created the following internal controls and governance: 1. Creation of the FFATA Reporting Form which will be completed and submitted along with all future subaward agreements and includes all necessary information for complete and accurate submittal into FSRS. 2. Creation of the FFATA Subrecipient Reporting Work Instructions which detail the process, to include roles and responsibilities, for the completion and entry of the FFATA. 3. Update to our Grant Administration Policy which includes the requirement to complete and enter the FFATA in our grant administration oversight and track timely submission of the reports. Name of the contact persons responsible for corrective action: Katherine Smith Planned completion date for corrective action plan: September 30, 2024

Categories

Reporting Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 478999 2023-001
    Material Weakness
  • 479000 2023-001
    Material Weakness
  • 479001 2023-001
    Material Weakness
  • 479002 2023-001
    Material Weakness
  • 479003 2023-001
    Material Weakness
  • 479004 2023-001
    Material Weakness
  • 479005 2023-001
    Material Weakness
  • 479006 2023-001
    Material Weakness
  • 479007 2023-001
    Material Weakness
  • 479008 2023-001
    Material Weakness
  • 479009 2023-001
    Material Weakness
  • 479010 2023-001
    Material Weakness
  • 479011 2023-001
    Material Weakness
  • 479012 2023-001
    Material Weakness
  • 479013 2023-001
    Material Weakness
  • 479014 2023-002
    Significant Deficiency
  • 479015 2023-002
    Significant Deficiency
  • 479016 2023-002
    Significant Deficiency
  • 479017 2023-002
    Significant Deficiency
  • 479018 2023-002
    Significant Deficiency
  • 479019 2023-002
    Significant Deficiency
  • 479020 2023-002
    Significant Deficiency
  • 1055440 2023-001
    Material Weakness
  • 1055441 2023-001
    Material Weakness
  • 1055442 2023-001
    Material Weakness
  • 1055443 2023-001
    Material Weakness
  • 1055444 2023-001
    Material Weakness
  • 1055445 2023-001
    Material Weakness
  • 1055446 2023-001
    Material Weakness
  • 1055447 2023-001
    Material Weakness
  • 1055448 2023-001
    Material Weakness
  • 1055449 2023-001
    Material Weakness
  • 1055450 2023-001
    Material Weakness
  • 1055451 2023-001
    Material Weakness
  • 1055452 2023-001
    Material Weakness
  • 1055453 2023-001
    Material Weakness
  • 1055454 2023-001
    Material Weakness
  • 1055455 2023-001
    Material Weakness
  • 1055456 2023-002
    Significant Deficiency
  • 1055457 2023-002
    Significant Deficiency
  • 1055458 2023-002
    Significant Deficiency
  • 1055459 2023-002
    Significant Deficiency
  • 1055460 2023-002
    Significant Deficiency
  • 1055461 2023-002
    Significant Deficiency
  • 1055462 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.575 Child Care and Development Block Grant $11.92M
93.778 Medical Assistance Program $6.06M
20.205 Highway Planning and Construction $5.28M
93.563 Child Support Enforcement $5.27M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $2.98M
21.023 Emergency Rental Assistance Program $2.70M
93.659 Adoption Assistance $2.51M
81.042 Weatherization Assistance for Low-Income Persons $1.15M
93.568 Low-Income Home Energy Assistance $1.09M
21.027 Coronavirus State and Local Fiscal Recovery Funds $940,771
17.278 Wia Dislocated Worker Formula Grants $768,908
17.207 Employment Service/wagner-Peyser Funded Activities $603,098
97.067 Homeland Security Grant Program $583,807
93.569 Community Services Block Grant $579,943
93.658 Foster Care_title IV-E $535,350
17.270 Reintegration of Ex-Offenders $454,847
93.268 Immunization Cooperative Agreements $394,586
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $380,143
93.645 Stephanie Tubbs Jones Child Welfare Services Program $315,660
17.277 Workforce Investment Act (wia) National Emergency Grants $288,571
16.606 State Criminal Alien Assistance Program $253,582
17.259 Wia Youth Activities $208,649
93.940 Hiv Prevention Activities_health Department Based $183,037
17.268 H-1b Job Training Grants $175,393
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $139,281
10.551 Supplemental Nutrition Assistance Program $124,890
93.558 Temporary Assistance for Needy Families $124,201
17.285 Apprenticeship USA Grants $122,541
93.217 Family Planning_services $119,999
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $119,618
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $117,895
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $96,434
97.042 Emergency Management Performance Grants $92,982
93.994 Maternal and Child Health Services Block Grant to the States $76,256
93.667 Social Services Block Grant $65,595
14.218 Community Development Block Grants/entitlement Grants $64,070
93.917 Hiv Care Formula Grants $58,833
93.069 Public Health Emergency Preparedness $52,836
15.437 Minerals Leasing Act $50,880
17.225 Reemployment Services and Assessment (resea) Program $45,859
93.090 Guardianship Assistance $41,705
93.556 Promoting Safe and Stable Families $41,020
95.001 High Intensity Drug Trafficking Areas Program $33,147
17.280 Workforce Investment Act (wia) Dislocated Worker National Reserve Demonstration Grants $25,735
17.258 Wia Adult Program $25,708
14.239 Home Investment Partnerships Program $25,679
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $23,909
17.245 Trade Adjustment Assistance $22,919
16.738 Edward Byrne Memorial Justice Assistance Grant Program $21,960
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $19,277
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $18,308
93.317 Emerging Infections Programs $14,153
93.747 Elder Abuse Prevention Interventions Program $12,610
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $11,707
16.607 Bulletproof Vest Partnership Program $8,633
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $8,177
17.801 Jobs for Veterans State Grants $8,006
16.543 Missing Children's Assistance $6,620
17.804 Local Veterans' Employment Representative Program $4,003
20.600 State and Community Highway Safety $2,261
93.472 Title IV-E Prevention and Family Services and Programs (a) $594