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.