Finding 480325 (2023-007)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2024-08-02
Audit: 316551
Organization: City of Banning (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The City lacks written procedures for determining the allowability of costs as required by federal guidelines.
  • Impacted Requirements: This finding indicates a significant deficiency in internal control and non-compliance with Title 2 CFR Section 200.302(b)(7).
  • Recommended Follow-Up: The City should develop and formalize policies and procedures for allowable costs in line with federal cost principles.

Finding Text

2023-007 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control and Instance of Non-Compliance Criteria: Title 2 CFR Section 200.302(b)(7) of the Uniform Guidance requires all non-Federal entities establish written procedures to implement the requirements for determining the allowability of costs in accordance with Subpart E – Cost Principles or the conditions of the Federal award. Condition: The City has not established written procedures for determining allowability of costs in accordance with Subpart E – Cost Principles or the conditions of the Federal award. Cause: The City’s procedures did not ensure the required written procedures were developed and implemented in accordance with the Uniform Guidance. Effect: The City has not compiled with Title 2 CFR Section 200.302(b)(7) regarding establishing written procedures for determining the allowability of costs. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The condition above was identified during our procedures related to allowable costs. Repeat Finding from Prior Year: No Recommendation: We recommend the City establish policies and formalize written procedures related to allowable costs in accordance with Subpart E – Cost Principles. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Corrective Action Plan

2023-007 – Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Finding Summary: Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control and Instance of Non-Compliance Corrective Action Plan: The city is in the process of updating its Purchasing Policy and will include language on allowable costs and cost principles that are compliant with 2 C.F.R. 200. The Purchasing Policy requires updates at least every five years and will be taken to City Council before the end of 2024 for approval by Resolution. Responsible Individual(s): Lincoln Bogard, Administrative Services Director; A’ja Wallace, Deputy Finance Director; and Barbara Mason, Purchasing Manager Anticipated Completion Date: December 2024

Categories

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 480324 2023-006
    Material Weakness
  • 1056766 2023-006
    Material Weakness
  • 1056767 2023-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19 Oronavirus State and Local Fiscal Recovery Funds $752,115
14.231 Covid-19 Emergency Solutions Grant Program $333,596
15.507 Watersmart (sustaining and Manage America's Resources for Tomorrow) $37,494
20.205 Highway Planning and Construction $29,385
20.106 Covid-19 Airport Improvement Program $23,484
14.218 Community Development Block Grants/entitlement Grants $10,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $9,227
16.034 Coronavirus Emergency Supplemental Funding Program $1,188