Finding 524150 (2024-003)

Significant Deficiency
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2025-02-21
Audit: 343340
Organization: City of Santa Fe (NM)

AI Summary

  • Core Issue: The City submitted reimbursement requests late for multiple months in the Federal Transit Cluster and only at year-end for the Airport Improvement Program.
  • Impacted Requirements: The City failed to maintain effective internal controls as required by 2 CFR 200.303(a) and 200.302b, affecting compliance with federal regulations.
  • Recommended Follow-Up: Implement stronger controls for timely review and approval of reimbursement requests to improve cash flow and reduce error risks.

Finding Text

2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526 Federal Awarding Agency: Department of Transportation Federal Award ID Number: N/A Federal Award Year: 2024 Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021 Federal Award Year: 2024 Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program. Criteria: Per 2 CFR 200.303(a), the non-federal entity must 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). Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective control over, and accountability for, all funds, property, and other assets. The non-federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. Cause: The City does not have sufficient controls in place to review and approve requests to submit as needed. Questioned Cost: None. Effect: The City’s financial position and cash balances were adversely affected due to the delay in requesting and receiving reimbursement for funds already disbursed. Significant time passing between disbursement of funds and preparation of reimbursement requests may increase the chance of errors.

Corrective Action Plan

Auditor recommendation: We recommend that the City establish policies and procedures for requesting reimbursement of grant expenditures on a monthly basis, including reconciliation of the expenditures and reimbursements under each grant. Views of Responsible Officials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this finding. Vacancies in key posi􀀁ons including the Airport Manager and the Transit Director of Administra􀀁on meant that there was not sufficient exper􀀁se in the program areas to ensure that reimbursement requests were prepared and submi􀀂ed 􀀁mely. These key posi􀀁ons have now been filled. The City now has an Airport Manager with substan􀀁al experience managing municipal airports and overseeing federal funding for airports. The City also hired a Transit Director of Administra􀀁on with extensive federal and state grant management experience, and exper􀀁se in Transit programs. The Accoun􀀁ng Officer, Grants Manager and Accoun􀀁ng Financial Analyst posi􀀁ons in the Finance Department have been filled, and the Grants Division is now fully staffed. More robust staffing is allowing Finance to perform more oversight in addi􀀁on to working more closely with Transit and Airport program staff. Filling these key posi􀀁ons and retaining qualified staff is essen􀀁al to establishing a process for 􀀁mely requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursement under each grant. The Transit Division is working with a contractor provided by the FTA on establishing policies and procedures to ensure compliance with federal grant requirements. This contractor is also providing training and technical assistance to the Transit program. The scope of this work includes ensuring requests for reimbursement of grant expenditures are submi􀀂ed 􀀁mely, and reconcilia􀀁ons of grant expenditures and reimbursements are completed 􀀁mely and accurately. The Airport Department is in the process of contrac􀀁ng with a vendor to assist with federal compliance and provide training for Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will include helping with developing and documen􀀁ng policies and standard opera􀀁ng procedures for requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursements. Addi􀀁onally, the Airport Department plans to create a Grant Accountant posi􀀁on which will be responsible for reconciling grant expenditures monthly and processing reimbursement requests quarterly. In CY25 the City plans to provide Uniform Guidance training for staff which will include internal controls related to cash management. Responsible Official:Emily Oster, Finance Director, James Harris, Airport Manager, Airport Heavy Equipment Mechanic, Gabrielle Chavez, Transit Director of Administration, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

Categories

Cash Management Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 524151 2024-004
    Significant Deficiency Repeat
  • 524152 2024-005
    Material Weakness Repeat
  • 524153 2024-003
    Significant Deficiency
  • 524154 2024-004
    Significant Deficiency Repeat
  • 524155 2024-005
    Material Weakness Repeat
  • 524156 2024-003
    Significant Deficiency
  • 524157 2024-003
    Significant Deficiency
  • 524158 2024-003
    Significant Deficiency
  • 524159 2024-006
    Significant Deficiency
  • 1100592 2024-003
    Significant Deficiency
  • 1100593 2024-004
    Significant Deficiency Repeat
  • 1100594 2024-005
    Material Weakness Repeat
  • 1100595 2024-003
    Significant Deficiency
  • 1100596 2024-004
    Significant Deficiency Repeat
  • 1100597 2024-005
    Material Weakness Repeat
  • 1100598 2024-003
    Significant Deficiency
  • 1100599 2024-003
    Significant Deficiency
  • 1100600 2024-003
    Significant Deficiency
  • 1100601 2024-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19: Coronavirus State and Local Fiscal Recovery Funds $4.23M
20.507 Federal Transit Formula Grants - Ridefinder Transit Enhancement $3.69M
20.507 Covid-19: Federal Transit Formula Grants -Coronavirus Response and Relief Supplemental Appropriations Act $1.66M
14.218 Community Development Block Grants/entitlement Grants $1.51M
20.106 Covid-19: Airport Improvement Program #51 $902,589
20.106 Covid-19: Airport Improvement Program #57 $876,014
20.526 Federal Transit Formula - Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions $531,610
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $347,268
93.053 Nutrition Services Incentive Program $123,817
93.045 Special Programs for the Aging, Title Iii, Part C-1, Nutrition Services $99,163
93.052 National Family Caregiver Support, Title Iii, Part E $87,833
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $68,877
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $65,053
97.067 Homeland Security Grant Program $54,614
93.045 Special Programs for the Aging, Title Iii, Part C-2, Nutrition Services $46,806
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $37,500
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $36,951
14.218 Covid-19: Community Development Block Grants/entitlement Grants $36,015
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $33,335
97.042 Emergency Management Performance Grants $26,751
94.011 Americorps Seniors Foster Grandparent Program (fgp) 94.011 $25,198
45.024 Promotion of the Arts Grants to Organizations and Individuals $20,000
95.001 High Intensity Drug Trafficking Areas Program $8,949