Finding 551113 (2024-002)

Material Weakness
Requirement
P
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 352034
Organization: City of Rancho Cordova (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The City reported expenditures of $638,418 that were not approved by FEMA, indicating a material weakness in internal controls.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) requires effective internal controls to ensure only eligible expenditures are reported on the SEFA.
  • Recommended Follow-Up: The City should strengthen controls to ensure only obligated expenditures are reported and review the internal control process.

Finding Text

Program/Cluster: Disaster Grants – Public Assistance Federal Financial Assistance Listing: 97.036 Federal Agency: U.S. Department of Federal Emergency Management Agency Pass-through: California Governor’s Office of Emergency Services Award No. and Year: FEMA-4683-DR-CA (2024) Compliance Requirement: O – Other Information Type of Finding: Material Weakness in Internal Control Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. As outlined in the Disaster Grants – Public Assistance section of the Compliance Supplement, section IV, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA) when (1) FEMA has approved the nonfederal entity’s Project, and (2) the nonfederal entity has incurred the eligible expenditures. Condition: Our testing over activities allowed and allowable costs identified three expenditures that were not approved under the grant per communications from the Federal Emergency Management Agency (FEMA). The City is currently appealing FEMA’s decision and pending project approval. For purposes of reporting expenditures on the Schedule of Expenditures of Federal Awards (SEFA), the City has removed total costs of $638,418 for the FEMA grant until obligations are approved. Cause: There was a lapse in oversight of the internal control process ensuring only obligated FEMA expenditures are reported on the SEFA. Effect: The City’s control did not detect or correct the errors identified, which resulted in expenditures being allocated to the federal award that were not obligated. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A haphazard sample of six transactions were selected for testing, which accounted for $729,981 of the original $965,040 reported as federal program expenditures. As a result of testing and review of the SEFA, the City revised the SEFA to only include approved obligations in the amount of $326,622. Repeat Finding from Prior Year(s): No. Recommendation: We recommend the City review and strengthen the controls surrounding expenditures being claimed under the grant and ensuring expenditures are obligated before being reported on the SEFA. Views of Responsible Officials: Management’s Response: See separate corrective action plan.

Corrective Action Plan

Program/Cluster: Disaster Grants – Public Assistance Federal Financial Assistance Listing Number: 97.036 Federal Grantor: U.S. Department of Federal Emergency Management Agency Pass-through: California Governor’s Office of Emergency Services Award Year: 2024 Grant Award Number: FEMA-4683-DR-CA Compliance Requirement: P – Other Information Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The noncompliance resulted from staff managing these records not being fully aware of the FEMA program compliance supplement that states expenditures are to be reported on the SEFA once they are approved and obligated. The City of Rancho Cordova will implement the following corrective actions: • Ensure all relevant personnel within the city are aware of FEMA’s specific documentation requirements. • Review and revise internal procedures to strengthen controls over grant expenditures to include documentation that supports the status of FEMA’s review of the eligible project cost • Implement a tracking system to ensure all future expenditures have been both approved and obligated by FEMA prior to being included on the SEFA, regardless of the year in which the expenditure was incurred. These measures will ensure that all future costs claimed are allowable, approvals properly supported, and in full compliance with FEMA regulations. Name of Responsible Person: Kim Juran, Administrative Services Director Projected Implementation Date: January 1, 2025

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1127555 2024-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Covid - 19 Coronavirus State and Local Fiscal Recovery Funds $3.11M
20.205 Highway Planning and Construction $2.52M
14.218 Community Development Block Grants/entitlement Grants $663,978
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $326,622
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $173,554
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $138,326
14.218 Covid - 19 Community Development Block Grants/entitlement Grants $60,695
97.039 Hazard Mitigation Grant $57,995
20.614 National Highway Traffic Safety Administration (nhtsa) Discretionary Safety Grants and Cooperative Agreements $15,633