Finding 548679 (2024-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: The City failed to report subawards to the FSRS on time, violating federal requirements.
  • Impacted Requirements: Noncompliance with 2CFR Part 170 and the compliance supplement, risking future grant funding.
  • Recommended Follow-Up: Implement a tracking system to ensure timely reporting of subawards and deadlines.

Finding Text

Federal Program CDBG-Entitlement Grants Cluster, AL 14.218 Criteria The requirements of 2CFRPart170 Appendix A states that direct recipients of grants or cooperative agreements are required to report first-tier subawards of $50,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Report System (FSRS) by the end of the following month in which the direct recipient awards such subawards. Part 3 of the compliance supplement requires this reporting at the $30,000. Condition During the audit, we noted reporting of subaward information to FSRS was not performed within the required timeframe. Cause The City did not have controls in place to ensure FSRS reporting was completed in the required timeframe. Identification as a Repeat Finding Reported as finding 2023-001 in the prior year. Effect The City could jeopardize future grant funding due to program noncompliance. Questioned Costs None. Context/Sampling In fiscal year 2023, a nonstatistical sample of two subrecipient agreements entered within the fiscal year under audit were selected to review FSRS submissions. This accounted for $77,454 of federal expenditures. Upon follow-up with the City regarding the correction of finding 2023-001, they were unable to provide evidence that the City had implemented the necessary corrective action. As a result, this finding will remain as a repeat finding. Recommendation We recommend the City implement a tracking system to remind staff of the various reports due and respective deadlines. Management’s Response See Corrective Action Plan.

Corrective Action Plan

Subrecipient Agreements Significant Deficiency and Non-Material Noncompliance Recommendation: We recommend the City review 2CFR200 to ensure information required in subrecipient agreements is properly included. Corrective Action: The Housing and Homelessness Division is aware of the deficiency identified and is actively coordinating with the City’s legal department to incorporate the required information into the City’s subrecipient agreement templates. Staff will review the 2CFR200 and ensure the required information is incorporated into the City’s sub-recipient agreement templates. Person Responsible for Corrective Action: The Housing and Division Managers, Senior Management Analyst, City’s Legal Department. Anticipated Completion Date for Corrective Action: 8 Weeks from approval of this corrective action plan 2024-03 – Subaward Reporting Requirements for Federal Funding Accountability and Transparency Act (FFATA) Significant Deficiency and Non-Material Noncompliance Recommendation: We recommend the City implement a tracking system to remind staff of the various reports due and respective deadlines. Corrective Action: Develop and implement an agreement routing cover page or other tracking system for all agreements, including sub-recipient agreements. This system will consist of required action items, including various Federal, State, and Local reports due and respective deadlines necessary to comply with sub-award reporting requirements consistent with the Federal Funding Accountability and Transparency Act (FFATA) and other applicable reporting requirements. Person Responsible for Corrective Action: The Housing and Homelessness Division’s Senior Management Analyst Anticipated Completion Date for Corrective Action: 4 Weeks from approval of this corrective action plan.

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 548680 2024-002
    Significant Deficiency
  • 548681 2024-002
    Significant Deficiency
  • 1125121 2024-002
    Significant Deficiency
  • 1125122 2024-002
    Significant Deficiency
  • 1125123 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $5.58M
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.31M
16.922 Equitable Sharing Program $433,918
97.067 Homeland Security Grant Program $426,849
14.231 Emergency Solutions Grant Program $378,719
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $368,089
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $355,001
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $222,512
16.609 Project Safe Neighborhoods $192,560
20.600 State and Community Highway Safety $187,904
14.239 Home Investment Partnerships Program $168,008
16.738 Edward Byrne Memorial Justice Assistance Grant Program $133,258
84.002A Adult Education - Basic Grants to States $122,786
20.235 Commercial Motor Vehicle Operator Safety Training Grants $67,425
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $49,221
97.042 Emergency Management Performance Grants $39,950
21.016 Equitable Sharing $9,574
14.264 Neighborhood Stabilization Program $4,650
21.023 Emergency Rental Assistance Program $2,970