Finding 480511 (2023-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-08-06
Audit: 316703
Auditor: Crowe LLP

AI Summary

  • Core Issue: Quarterly progress and financial reports lack a separate reviewer, risking undetected errors.
  • Impacted Requirements: Reports must comply with FRA guidelines and the Federal Funding Accountability and Transparency Act, which was not met timely.
  • Recommended Follow-Up: Implement a system where two individuals prepare and review reports, and track deadlines to ensure timely submissions.

Finding Text

Criteria: Reporting requirements are identified in Part III, Grant Management Terms and Conditions, of the award agreement with the Federal Railroad Administration. The Grantee will submit one completed progress report quarterly (totaling four annually) in the form/format provided by FRA. Additionally, the Grantee will submit the Federal Financial Report (Standard Form 425) on the same schedule as the required quarterly progress report. Finally, the Grantee will comply with the provisions of the Federal Funding Transparency and Accountability Act of 2006. Condition/Context: During our testing of internal controls over reporting, we noted the quarterly progress report and federal financial reports are prepared by the Project Grant Administrator, however there was no separate reviewer. Additionally, for the Federal Funding Accountability and Transparency Act, the submission is no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. The award was obligated in May 2021; however, the submission did not occur until November 2023, therefore it did not occur timely. Effect: As there was no secondary review of quarterly reports, errors in reporting could go undetected. Cause: Management had not established a proper system of internal control over grant reporting to prevent and detect errors in reporting. Identification as a Repeat Finding: N/A Recommendation: We recommend that the quarterly reporting be prepared and reviewed by two separate individuals for proper segregation of duties. Additionally, we recommend that the Authority track reporting requirements and deadlines to ensure timely submission. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

Views of Responsible Official: The Project Grant Administrator did prepare and submit the FRA quarterly reports. This person was the official reviewer of the project progress for the FRA quarterly report submission. The financial information for the report was first compiled by the Capital Projects and Grant Tracking (CPGT) Administrator Accountant. (Note that CPGT is reconciled with CODA, the SORTA accounting system, before this information is provided.) The Project Grant Administrator received project implementation information from the Construction Project Manager. The Grant Administrator married this information with what was provided by the CPGT Administrator/Accountant, as well as what was in Maximo (the SORTA procurement system), The Project Grant Administrator also visited the project site to verify progress of the FRA project(s) when needed. The final quarterly reports were used by the Director of Grants as well as FRA to keep up with the implementation progress of the project(s). Any actual draw down of funding for the project was prepared separately by the CPGT Administrator/Accountant and signed off by the Director of Accounting. We concur with the finding that the FFATA report for reporting of an award to a subrecipient above a certain dollar threshold was submitted in November of 2023, which was after the regulatory date for submission. Description of Corrective Action Plan: The Federal Railroad Administration (FRA) CRISI Grant- that this finding relates to has been completed and is now closed. Thus, there will not be any further Quarterly reports prepared or submitted under this particular Grant. And, it is not anticipated that SORTA will be administering any other FRA CRISI Grants in the foreseeable future. In relation to the FFATA reporting, the Grants Department will add the FFATA reporting requirements to the Grants Processes and Procedures so that should SORTA encounter a grant subrecipient situation with a future grant, Grants staff will have a reminder and reference to help ensure the reporting requirements are performed in a timely manner. Responsible Party and Timeline for Completion: Federal regulation requires name and title of person overseeing corrective action plan and anticipated completion date. The Director or Grants, Mary Huller, will complete the modification to the Processes and Procedures to include FFATA reporting requirements by the end of August 2024.

Categories

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

  • 1056953 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.507 Federal Transit_formula Grants $17.51M
20.325 Consolidated Rail Infrastructure and Safety Improvements $3.73M