Finding 518889 (2024-001)

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Requirement
P
Questioned Costs
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Year
2024
Accepted
2025-01-13
Audit: 337320
Organization: City of Rochester, New York (NY)

AI Summary

  • Core Issue: Subrecipients lack key information about the Federal program due to incomplete award letters.
  • Impacted Requirements: Award letters did not include the required assistance listing number as per Code of Federal Regulations §200.332.
  • Recommended Follow-Up: Revise grant award letters to ensure compliance and prevent future omissions; involve the Law Department in contract approvals.

Finding Text

Federal Agency - United States Department of the Treasury Federal Program - Coronavirus State and Local Fiscal Recovery Funds (21.027) Federal Award Year - 2021 State Agency - None Reference: 2024-001 Criteria - Code of Federal Regulations §200.332 lists the requirements that must be clearly identified to subrecipients. Condition - The subrecipients may not have a full understanding of the Federal program. Key information, including identifying the assistance listing number, was not identified on the award letters given to the subrecipients. Cause - The award letters to the subrecipients did not include all required information. Effect of Condition - Subrecipients do not have all the relevant information and, therefore, may not comply with Federal program requirements. Questioned Costs - None. Perspective - Noted that award letters given to the tested subrecipients were missing key information, including identifying the assistance listing number. Recommendation - We recommend that the City revise its grant award letters to be in compliance with Code of Federal Regulations §200.332. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Management's  Response - The City recognizes that the requirement of providing the identifying assistance listing number was not provided on certain ARPA contracts awarded through the Department of Recreation and Human Services. It is the City's practice to include this information in all contracts where federal funds are awarded. In November of 2024 when it was identified that there were a number of subrecipients that had not been notified of this required information, the Department of Recreation and Humans Services emailed all subrecipients who had not previously been provided this information. In order to prevent this requirement from being overlooked in the future, the Law Department has also been informed of this requirement. The Law Department is in the approval process for all contracts and will not provide their approval until this requirement is met.

Corrective Action Plan

Management's  Response - The City recognizes that the requirement of providing the identifying assistance listing number was not provided on certain ARPA contracts awarded through the Department of Recreation and Human Services. It is the City's practice to include this information in all contracts where federal funds are awarded. In November of 2024 when it was identified that there were a number of subrecipients that had not been notified of this required information, the Department of Recreation and Humans Services emailed all subrecipients who had not previously been provided this information. In order to prevent this requirement from being overlooked in the future, the Law Department has also been informed of this requirement. The Law Department is in the approval process for all contracts and will not provide their approval until this requirement is met.

Categories

Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $54.22M
14.218 Community Development Block Grants/entitlement Grants $9.00M
20.205 Highway Planning and Construction $8.41M
14.239 Home Investment Partnerships Program $2.48M
14.905 Lead Hazard Reduction Demonstration Grant Program $1.22M
14.241 Housing Opportunities for Persons with Aids $1.06M
14.231 Emergency Solutions Grant Program $574,075
94.006 Americorps-Arp $532,011
14.231 Cares Act - Emergency Solutions Grant Program $424,096
94.006 Americorps $401,037
16.575 Crime Victim Assistance $355,083
93.778 Medical Assistance Program $295,996
93.235 Affordable Care Act (aca) Abstinence Education Program $238,771
16.922 Equitable Sharing Program $219,062
10.727 Ira Urban and Community Forestry $203,544
97.067 Homeland Security Grant Program $154,605
14.218 Cares Act - Community Development Block Grants/entitlement Grants $139,222
10.559 Summer Food Service Program for Children $133,464
16.738 Edward Byrne Memorial Justice Assistance Grant Program $124,139
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $98,127
66.815 Environmental Workforce Development and Job Training Cooperative Agreements $76,521
21.016 Equitable Sharing $62,811
93.994 Maternal and Child Health Services Block Grant to the States $62,129
20.616 National Priority Safety Programs $52,828
16.588 Violence Against Women Formula Grants $50,444
14.239 Home Investment Partnerships Program - Arp $23,104
16.835 Body Worn Camera Policy and Implementation $7,313
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $3,263