Finding 52250 (2022-101)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-29

AI Summary

  • Core Issue: Payments to 4 out of 15 subrecipients were not made within the required 30-day period due to missing or inaccurate information in their requests.
  • Impacted Requirements: Compliance with federal regulations (CFR 576.203(c)) regarding timely payments to subrecipients is at risk.
  • Recommended Follow-Up: Implement policies to document drawdown requests and maintain records to justify any payment delays.

Finding Text

Federal program information: Funding agencies: U.S. Department of Housing and Urban Development Titles: Emergency Shelter Grants Program Assistance Listing Number: 14.231 Award numbers: C21-0580, 152439-0, 152126-0, ADES18-206228 Pass-Through grantors: City of Glendale, Arizona, City of Phoenix, Arizona and Arizona Department of Economic Security Compliance Requirements: Special Tests ? Payments to Subrecipients Questioned Costs: N/A Criteria: Code of Federal Regulations ? 576.203(c) Obligation, expenditure and payment requirements state that recipients of ESG funds must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient?s complete payment request. Condition: For 4 of 15 subrecipient payments selected for review it was noted that the payments were not made within the 30 day allowable period. Per discussion with management it was determined that the payments were not made within the time limit as a result of missing or inaccurate information in the subrecipient?s drawdown requests. However, no additional documentation could be provided to show that items were missing from the drawdown requests. Cause and Effect: The organization does not have adequate policies and procedures in place to document the subrecipient drawdown review and they did not maintain adequate supporting documentation to show draw down requests were incomplete. The result is that there is increased chance of non-compliance with the requirements of the grant. Auditors? Recommendations: The organization should establish policies and procedures to ensure that drawdown requests are documented when received and should maintain adequate documentation to substantiate delays in payments made to subrecipients.

Corrective Action Plan

We agree with the auditor's comments. The following actions will be taken to make sure sub-recipients payments comply with the Code of Federal Regulations 576.203{c). We will pay invoices within 30 days or document the reason for any delay. We would like it noted that in most cases the late payments were due to incomplete payment requests from the sub-recipients. Unfortunately, our invoice review process did not include preserving our notes and communication with the sub-recipients regarding our questions and requests for missing documentation that ultimately lead to the submission of additional documentation from the subrecipients and final approval of the invoice payment.

Categories

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 52251 2022-101
    Significant Deficiency
  • 52252 2022-101
    Significant Deficiency
  • 628692 2022-101
    Significant Deficiency
  • 628693 2022-101
    Significant Deficiency
  • 628694 2022-101
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $7.72M
93.667 Social Services Block Grant $605,087
14.231 Emergency Solutions Grant Program $558,996
97.024 Emergency Food and Shelter National Board Program $285,233
93.558 Temporary Assistance for Needy Families $94,792
14.218 Community Development Block Grants/entitlement Grants $44,430