Finding 524151 (2024-004)

Significant Deficiency Repeat Finding
Requirement
AB
Questioned Costs
$1
Year
2024
Accepted
2025-02-21
Audit: 343340
Organization: City of Santa Fe (NM)

AI Summary

  • Core Issue: Duplicate payroll checks totaling $2,694 were included in reimbursement requests, indicating a significant deficiency in internal controls.
  • Impacted Requirements: The City failed to comply with 2 CFR 200.303(a) and 2 CFR 200.430(f), which mandate effective internal controls and prohibit charging duplicate costs to federal programs.
  • Recommended Follow-Up: Strengthen internal controls to ensure accurate payroll reporting and prevent duplicate reimbursements in future submissions.

Finding Text

2024-004 (2023-004) – Activities Allowed, Allowable Costs over Payroll (Significant Deficiency in Internal Controls over Compliance) (Repeated/Modified) Federal Program Information 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-3-35-0037-057-2021 Federal Award Year: 2024 Condition: Two payroll checks were duplicated and included in the request for reimbursement. These checks totaled $2,694, out of a total of $876,014 in payroll charged to the program. Management’s Progress on Repeat Findings: Some progress made from prior year. 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 2 CFR section 200.430(f) – Factors affecting allowability of costs, costs charged to Federal programs may not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on the general ledger as charged to the grant. Questioned Cost: Known and likely questioned costs of $2,694 Effect: The City requested and received reimbursement for duplicate transactions not properly allocable to the program in the amount of $2,694.

Corrective Action Plan

Auditor recommendation: The auditor recommends that the City implement a final review for potential duplicated costs prior to approving reimbursement requests, and adjust the general ledger for any such items noted. Views of Responsible Officials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this finding. A reimbursement request was submi􀀂ed 3/18/24 in the amount of $634,532.45. It was later iden􀀁fied that the reimbursement request included duplicate payroll expenditures in the amount of $2,694. One of the duplicated items, totaling $1,115, was iden􀀁fied through internal review within the City of Santa Fe a􀀃er the reimbursement request was submi􀀂ed. A credit memo has been processed in the FAA’s Delphi system and the City has repaid the $1,115 amount that was duplicated. The other item, totaling $1,579, was iden􀀁fied through the external audit. The City will process an addi􀀁onal credit memo and repay the $1,579 amount promptly. The Finance Director, the Accoun􀀁ng Officer, and the Grants team are working with the Airport team to strengthen policies and procedures and ensure a full review of the general ledger for the federal program to ensure no duplicate costs are charged prior to reimbursement requests being submi􀀂ed. A secondary review by the Finance Department of all Airport requests for reimbursement is now occurring prior to submission to FAA. In addi􀀁on, we have started using employee pay advices as addi􀀁onal suppor􀀁ng documenta􀀁on for reimbursement requests. In the past excel spreadsheets were used as suppor􀀁ng documenta􀀁on, and the Finance Department review some􀀁mes happened a􀀃er the reimbursement request was submi􀀂ed. Vacancies in key posi􀀁ons resulted in a lack of robust review of reimbursement requests prior to submission. 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 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 work more closely with the Airport team. One of the primary du􀀁es of the new Accoun􀀁ng Financial Analyst in the Grants Division is to support the administra􀀁on of Airport grants. The City is in the process of contrac􀀁ng with a vendor to assist the Airport 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. 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. The Finance Department will con􀀁nue to perform a secondary review of Airport requests for reimbursement prior to submission to FAA. In CY25 the City plans to provide Uniform Guidance training for staff which will include internal controls related to ac􀀁vi􀀁es allowed and allowable costs. Responsible Official: Emily Oster, Finance Director, James Harris, Airport Manager, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

Categories

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Other Findings in this Audit

  • 524150 2024-003
    Significant Deficiency
  • 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