Finding 50009 (2022-001)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-03-30
Audit: 48716
Organization: County of Contra Costa (CA)

AI Summary

  • Core Issue: The County failed to report subawards over $30,000 as required by FFATA, leading to noncompliance.
  • Impacted Requirements: Reporting obligations under Title 2, Part 170 of OMB guidance for federal grants were not met.
  • Recommended Follow-up: Update practices for identifying and submitting subaward reports to ensure timely compliance with FFATA requirements.

Finding Text

Reference Number: 2022-001 Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Cluster Assistance Listing Number: 93.600 Federal Award Numbers: 09CH010862-04-02 and 09HE000903-01-00 Category of Finding: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria Title 2 ? Grants and Agreements. Subtitle A ? Office of Management and Budget Guidance for Grants and Agreements. Chapter I ? Office of Management and Budget Government-wide Guidance for Grants and Agreements. Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170, Section I(a) (a) Reporting of first-tier subawards. 1. Applicability. Unless you are exempt as provided in paragraph d. of this award term, you must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency. 2. Where and when to report. i. The non-Federal entity or Federal agency must report each obligating action described in paragraph a.1. of this award term to http://www.fsrs.gov. ii. For subaward information, report no later than the end of the month following the month in which the obligation was made. Condition We examined the Federal Funding Accountability and Transparency Act (FFATA) reporting for the Head Start Cluster for the year ended June 30, 2022. The required FFATA reporting submissions pertaining to subrecipient awards were not made. Cause The County did not submit FFATA reporting because they were not aware of the reporting requirements. Questioned Costs No questioned costs were identified. Context Expenditures for the fiscal year 2021-22 totaled $25,414,728. Pass through payments to subrecipients subject to FFATA reporting were $6,172,353. Effect Failure to report subawards greater than $30,000 under FFATA is considered noncompliance with the transparency requirement established by the federal government. Recommendation We recommend that the County update its current practices for managing subaward reporting under the FFATA to ensure that applicable subawards are identified and the required submissions are made timely. Views of Responsible Officials and Corrective Action Plan Management?s response is reported in ?Corrective Action Plan? included in a separate section at the end of this report.

Corrective Action Plan

Corrective Action Plan For the Year Ended June 30, 2022 Reference Number: 2022-001 Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Cluster Assistance Listing Number: 93.600 Federal Award Numbers: 09CH010862-04-02 and 09HE000903-01-00 Category of Finding: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance The Employment and Human Services Department will comply with Appendix A (I)(a) of 2 CFR Part 170 to report each obligating action greater than or equal to $30,000 in Federal funds for a subaward to a non-Federal entity no later than the end of the month following the month in which the obligation was made. When applicable, the Employment and Human Services Department will require that its subrecipient provide their executive total compensation. The Employment and Human Services Department will report the information per 2 CFR 170 Appendix A, and the grant award instructions. The Employment and Human Services Department?s fiscal management will work with fiscal staff to develop a FFATA tracking tool for designated fiscal staff to use to meet the reporting requirement of Head Start. EHSD designated fiscal staff will be trained on the tracking tool and reporting requirement for completeness, accuracy and timeliness in accordance with 2 CFR 170 Appendix A, and the grant award instructions. Contact person responsible for corrective action plan: Marla Stuart, Director Contra Costa County Employment and Human Services Department Emilia Gabriele, Chief Deputy Director Contra Costa County Employment and Human Services Department Erik Brown, Chief Financial Officer Contra Costa County Employment and Human Services Department

Categories

Subrecipient Monitoring Material Weakness Reporting

Other Findings in this Audit

  • 50010 2022-001
    Material Weakness
  • 626451 2022-001
    Material Weakness
  • 626452 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $79.21M
93.778 Medical Assistance Program $34.18M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $25.94M
93.600 Head Start $25.13M
93.558 Temporary Assistance for Needy Families $20.29M
20.205 Highway Planning and Construction $14.72M
93.658 Foster Care_title IV-E $13.15M
93.563 Child Support Enforcement $12.20M
93.659 Adoption Assistance $11.51M
93.667 Social Services Block Grant $6.50M
93.575 Child Care and Development Block Grant $6.01M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $6.00M
14.231 Covid-19 Emergency Solutions Grant Program $5.84M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $4.64M
20.106 Airport Improvement Program $4.35M
14.218 Community Development Block Grants/entitlement Grants $3.98M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $3.55M
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $3.15M
93.958 Block Grants for Community Mental Health Services $2.67M
93.568 Low-Income Home Energy Assistance $2.58M
17.278 Wia Dislocated Worker Formula Grants $2.53M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $2.12M
93.268 Covid-19 Immunization Cooperative Agreements $2.11M
10.025 Plant and Animal Disease, Pest Control, and Animal Care $1.99M
17.258 Wia Adult Program $1.93M
93.914 Hiv Emergency Relief Project Grants $1.82M
16.575 Crime Victim Assistance $1.81M
93.090 Guardianship Assistance $1.65M
17.259 Wia Youth Activities $1.63M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $1.50M
93.498 Covid-19 Provider Relief Fund $1.49M
11.473 Office for Coastal Management $1.40M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $1.16M
93.224 Covid-19 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.11M
10.551 Supplemental Nutrition Assistance Program $1.10M
97.067 Homeland Security Grant Program $1.09M
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $1.04M
93.069 Public Health Emergency Preparedness $978,475
14.218 Covid-19 Community Development Block Grants/entitlement Grants $934,354
93.566 Refugee and Entrant Assistance_state Administered Programs $920,480
93.505 Affordable Care Act (aca) Maternal, Infant, and Early Childhood Home Visiting Program $919,650
16.738 Edward Byrne Memorial Justice Assistance Grant Program $829,750
66.126 The San Francisco Bay Water Quality Improvement Fund $751,055
93.569 Community Services Block Grant $726,547
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $705,374
93.556 Promoting Safe and Stable Families $698,444
93.184 Disabilities Prevention $697,715
93.917 Hiv Care Formula Grants $628,691
21.023 Covid-19 Emergency Rental Assistance Program $603,985
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $570,209
93.645 Stephanie Tubbs Jones Child Welfare Services Program $554,631
93.052 National Family Caregiver Support, Title Iii, Part E $549,620
14.241 Housing Opportunities for Persons with Aids $523,994
10.558 Child and Adult Care Food Program $515,897
93.045 Covid-19 Special Programs for the Aging_title Iii, Part C_nutrition Services $509,964
93.053 Nutrition Services Incentive Program $433,545
93.788 Opioid Str $429,710
93.940 Hiv Prevention Activities_health Department Based $421,557
16.741 Dna Backlog Reduction Program $398,251
93.268 Immunization Cooperative Agreements $388,512
16.320 Services for Trafficking Victims $338,236
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $336,137
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $335,604
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $335,153
93.994 Maternal and Child Health Services Block Grant to the States $320,205
14.267 Continuum of Care Program $313,335
14.231 Emergency Solutions Grant Program $302,561
17.277 Covid-19 Workforce Investment Act (wia) National Emergency Grants $288,205
93.600 Covid-19 Head Start $280,512
93.889 National Bioterrorism Hospital Preparedness Program $246,203
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $240,603
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $202,204
93.959 Covid-19 Block Grants for Prevention and Treatment of Substance Abuse $185,547
93.044 Covid-19 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $176,802
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $163,836
93.150 Projects for Assistance in Transition From Homelessness (path) $143,788
93.603 Adoption Incentive Payments $142,698
97.042 Emergency Management Performance Grants $141,233
93.317 Emerging Infections Programs $139,539
10.555 National School Lunch Program $131,824
14.241 Covid-19 Housing Opportunities for Persons with Aids $124,888
97.039 Hazard Mitigation Grant $123,939
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $121,216
93.568 Covid-19 Low-Income Home Energy Assistance $111,563
20.616 National Priority Safety Programs $109,067
93.876 Antimicrobial Resistance Surveillance in Retail Food Specimens $108,040
93.324 State Health Insurance Assistance Program $106,050
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $102,692
93.354 Covid-19 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $99,162
16.528 Enhanced Training and Services to End Violence and Abuse of Women Later in Life $87,227
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $73,910
93.945 Assistance Programs for Chronic Disease Prevention and Control $69,864
93.590 Community-Based Child Abuse Prevention Grants $63,632
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $58,124
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $48,049
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $39,880
93.071 Medicare Enrollment Assistance Program $35,148
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $34,800
20.106 Covid-19 Airport Improvement Program $32,000
66.312 State Environmental Justice Cooperative Agreement Program $30,480
93.958 Covid-19 Block Grants for Community Mental Health Services $26,974
81.042 Weatherization Assistance for Low-Income Persons $20,212
93.569 Covid-19 Community Services Block Grant $18,695
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $14,966
97.012 Boating Safety Financial Assistance $8,728
10.555 Covid-19 National School Lunch Program $7,614
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $6,500
14.239 Home Investment Partnerships Program $4,663
93.778 Covid-19 Medical Assistance Program $2,208
16.922 Equitable Sharing Program $1,034
21.016 Equitable Sharing $4