Finding 504821 (2022-006)

FINDING 2022-006 Subject: COVID-19 - Emergency Rental Assistance Program - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Emergency Rental Assistance Program Assistance Listings Number: 21.023 Federal Award Numbers and Years (or Other Identifying Numbers): ERA-0359, ERA2-0357 Compliance Requirement: Reporting Audit Findings: Significant Deficiency, Other Matters INDIANA STATE BOARD OF ACCOUNTS 26 LAKE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Recipients are required to submit FFATA (Federal Funding Accountability and Transparency Act) reporting through the FSRS (FFATA Subaward Reporting System) website to the U.S. General Services Administration. This reporting is required to be completed for each action based on subawards of $30,000 or more that are made from the federal program. Information to be reported included the information contained within the subaward. The County did not have any policies or procedures in place related to the FFATA reporting requirements. During the audit period, the County was required to submit the FFATA reporting for one subaward that was over $30,000. The County, however, did not submit the required report on the FSRS website. The lack of internal controls and noncompliance were isolated to the FFATA reporting in 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 170 Appendix A(I)(a) states in part: ". . . 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 . . ." Cause A system of internal controls over the FFATA reporting was not designed by management of the County to ensure the County provided the U.S. General Services Administration, as well as users of the FSRS website, with complete and accurate information related to the COVID-19 - Emergency Rental Assistance Program awards. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot ensure compliance with FFATA reporting requirements. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Additionally, the County not meeting the COVID-19 - Emergency Rental Assistance Program reporting requirements increases the likelihood that the U.S. General Services Administration, as well as users of the FSRS website, will not have access to transparent and accurate information regarding subawards of federal awards. INDIANA STATE BOARD OF ACCOUNTS 27 LAKE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County design and implement a proper system of internal controls to ensure that all subrecipients awarded $30,000 or more are properly reported in accordance with the FFATA reporting requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.