Finding Text
The Council’s internal controls were inadequate for ensuring compliance with federal reporting requirements for the Economic Assistance Adjustment Program.
Assistance Listing Number and Title: 11.307, COVID-19 Economic Adjustment Assistance
Federal Grantor Name: U.S. Department of Commerce Economic Development Administration
Federal Award/Contract Number: 07-79-07622
Pass-through Entity Name: N/A
Pass-through Award/Contract Number: N/A
Known Questioned Cost Amount: $0
Prior Year Audit Finding: N/A
Background
The primary objective of the Economic Adjustment Assistance program is to assist communities with revitalizing and expanding their physical and economic infrastructure and support the creation and retention of jobs for area residents by helping eligible recipients promote the economic development of their local economies.
To carry out the program objective, the Council distributes business loans from the money it receives from the U.S. Economic Development Administration (EDA) using a revolving loan fund (RLF). Qualified businesses in Benton and Franklin counties can apply to this program for a financial assistance business loan. In 2023, the Council reported a $1,803,471 outstanding loan balance for its Economic Adjustment Assistance program.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
The Council must submit semiannual financial reports to the EDA so it can monitor the Council’s management and use of program funds from the RLF. The EDA requires the Council to include in its reports key line items, or financial information the EDA considers critical in measuring how the Council manages program funds.
Description of Condition
The Council did not have internal controls to ensure the financial information it reported in the semiannual financial reports was accurate and supported.
We consider this internal control deficiency to be a material weakness that led to material noncompliance.
Cause of Condition
The Council experienced staff turnover and did not provide the Council employee responsible for submitting the semiannual reports adequate training to complete the reports accurately. Additionally, because the Council had limited access to the EDA portal where the financial reports are submitted, it did not establish a process to review the reports before submitting them.
Effect of Condition
The ED-209 report documents the number of loans, amount loaned and outstanding principal of both active and written-off loans, capital base, income used for administrative expenses, income earned, leverage and loan leverage ratio. These semiannual reports include information the EDA uses to conduct risk analysis ratings of each RLF recipient’s RLF program to assess the strengths and weaknesses of each and to identify RLFs that require additional monitoring, technical assistance or other corrective action. Failing to submit accurate and complete information to the EDA diminishes the federal government’s ability to monitor the Council’s RLF program.
Recommendation
We recommend the Council establish and follow internal controls to ensure compliance with federal laws and regulations. Specifically, we recommend the Council provide adequate training to staff that prepare the semiannual reports, and review financial information reported for completeness and accuracy in compliance with the program’s requirements.
Council’s Response
BFCOG concurs with this finding. An unfortunate comedy of errors led to the creation, submission, and acceptance of the FY2023 Mid-Year and Year-End Financial Reports for the EDA CARES Revolving Loan Fund activities. These errors included changes in BFCOG key staff at the end of 2022 and again mid-way through 2023, a lack of understanding by BFCOG staff of the EDA Portal and the report's pre-population and cumulation functions, a lack of documentation to support the submitted reports, and a lack of review for accuracy by BOTH BFCOG and EDA. The internal financial reports necessary to accurately complete the EDA Financial Reports were readily available, as was training on the EDA Portal and Report functions. BFCOG, indeed, was lacking internal controls.
It is important to note that the EDA RLF Administrator accepted both reports as submitted and without requesting correction, even though they had nearly identical data to the 2022 year-end report. Had either report been returned by EDA for correction, the problem could have been identified and corrected promptly.
Auditor’s Remarks
We appreciate the Council’s commitment to resolve this finding and thank the Council for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.