Finding 530192 (2024-001)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2024
Accepted
2025-03-25
Audit: 348296
Organization: City of Paramount (CA)

AI Summary

  • Core Issue: The City failed to meet the required 10% level of effort for the project due to turnover in the Project Director position.
  • Impacted Requirements: This non-compliance could lead to sanctions from the U.S. Department of Education, including withholding future funds.
  • Recommended Follow-Up: Implement training and transition policies for key personnel and track the new Project Director's time to ensure compliance with the level of effort requirement.

Finding Text

Internal Control and Compliance over Level of Effort Identification of the Federal Program: Assistance Listing Number: 84.116z Assistance Listing Title: Fund for the Improvement of Postsecondary Education Federal Agency: Department of the Education Pass-Through Entity: None Federal Award Number and Award Year: P116Z220212 and 2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Grant Award Notification Section 5 – Key Personnel, the City is required to maintain level of effort of 10% devoting to the project by the Project Director. Condition: We noted that the City did not meet the requirements of level of effort based on the documents provided. Cause: There was turnover of the Project Director position and there is lack of transition and training on the program requirements. Effect or Potential Effect: Not meeting the requirements of level of effort lead to the U.S. Department of Education imposing sanctions on the City including withholding future apportionments. Questioned Costs: No questioned costs were reported. Context: See condition above for context of the finding. Identification as A Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City implement policies and procedures relating training and transition of program responsibilities in event of turnover to avoid not meeting program requirements. We also recommended the City develop a process and start tracking the time and effort of the new Project Director to ensure compliance with level of effort requirement. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.

Corrective Action Plan

The City concurs with the auditor's recommendation and will modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. The City has never had a finding in its Single Audit concerning the Level of Effort requirement. The Finance Department has drafted a Grant policy that is under review and will be approved administratively by City Manager John Moreno. The Policy instructs City staff members on the grant provisions for grant identification, grant funding analysis, administrative compliance, subrecipient monitoring, documentation, and restrictions. Upon approval, Financial Services Manager Anthony Martinez will inform and train all City staff members involved in the procurement and management of all grants. Within the components of training, City staff members will learn the requirements of the "Level of Effort" in the context of federal grants. Moreover, City staff members will learn how to satisfy and dedicate the Grant Project Manager's total work time toward the grant project while maintaining accurate documentation. In addition, Financial Services Manager Anthony Martinez will train staff in the succession of managing the responsibilities of grants to ensure all obligations are maintained during staff transitions. The Grant policy and internal training is part of a larger effort by the Finance Department to implement an administrative Fiscal Policy Manual and Fiscal Practices Training Group expected by June 30, 2025.

Categories

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1106634 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $283,139
84.116 Fund for the Improvement of Postsecondary Education $251,249
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $143,472
14.239 Home Investment Partnerships Program $119,498