Finding Text
Criteria: Internal controls should be in place to ensure that reporting requirements are met as specified in the
guidance provided by both the granting agency, as well as federal codifications. 2 CFR Part 170 guidance
specifies that direct recipients are required to report first‐tier subawards of $30,000 or more to the Federal
Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition and Context: During our testing of reporting requirements during the 2022 fiscal year it was noted
the City, as a direct recipient of U.S Department of Housing and Urban Development awards, was not timely
filing subawards through the Federal Funding Accountability and Transparency Act Subaward Reporting
System (FSRS). During the City’s fiscal year 2023, they continued to expend subawards on old HUD awards
from 2019, 2020, and 2021 for which the time period for timely filing has lapsed in prior years. Additionally,
the HUD award for grant year 2022 was received in September 2022 and the subawards were obligated prior
to being notified of the reporting requirement in the June 30, 2022 audit report. Therefore, the time line for
complying with the timely reporting was past for all federal awards 2022 and prior. During the City’s fiscal
year 2023, the City expended 3 subawards of $30,000 which in total amount to $226,630. All 3 were not
reported in the FSRS, due to the obligations being made in previous fiscal years. The current fiscal year award
for September 2022 was also not timely filed, though has been filed outside of the required timelines.
Cause: Per review of the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS), the City’s CDBG Program was not reporting any subrecipients for the program of award B‐21‐MC‐47‐
0002 and B‐23‐MW‐47‐0002. Additionally, obligations of programs award B‐22‐MC‐47‐0002 were not timely
filed, though ultiatmely filed late under the Federal Funding Accountability and Transparency Act. This was
due to oversight by the program management for the CDBG program.
Effects: The City was not in compliance with the reporting requirements.
Questioned Costs: None.
Recommendation: We recommend the City take necessary steps in the future to ensure that those
responsible for the program are aware of reporting requirements and have a process in place to ensure that
all reports and submissions are completed and submitted timely. We recommend that reporting
responsibilities be clearly communicated and delegated to one or two individuals.
Auditee’s Response: We concur with the finding. Due to changes in departmental management and
responsibilities submission was not timely. We have now implemented policies and procedures to ensure
grant activity is reported in accordance with the grant requirements.