Finding 556196 (2022-003)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2025-04-29
Audit: 354873
Organization: Benton County (WA)

AI Summary

  • Core Issue: Benton County lacked adequate internal controls for compliance with federal reporting requirements for the Emergency Rental Assistance Program, leading to material noncompliance.
  • Impacted Requirements: The County failed to submit three out of nine required monthly reports and did not include necessary data in the final quarterly report, affecting transparency and eligibility for fund reallocations.
  • Recommended Follow-up: Implement stronger internal controls to ensure timely submission of all monthly and accurate quarterly reports to meet federal requirements.

Finding Text

Benton County January 1, 2022 through December 31, 2022 2022-003 The County did not have adequate internal controls for ensuring compliance with federal reporting requirements for the Emergency Rental Assistance Program. Assistance Listing Number and Title: 21.023, COVID-19 Emergency Rental Assistance Program Federal Grantor Name: U.S. Department of the Treasury Federal Award/Contract Number: N/A Pass-through Entity Name: Pass-through Award/Contract Number: Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Description of Condition Congress passed two acts authorizing federal funds for the Emergency Rental Assistance (ERA) program to respond to the COVID-19 pandemic. The Consolidated Appropriations Act, 2021 was enacted on December 27, 2020, and provided $25 billion for ERA. These funds are known as ERA1. The American Rescue Plan Act of 2021 was enacted on March 11, 2021, and provided $21.6 billion in additional funding for ERA. These funds are known as ERA2. These acts provide funds directly to states, U.S. territories, local governments and, in the case of ERA1, Indian tribes to assist eligible households through existing or newly created rental assistance programs. The purpose of the ERA program is to provide direct payments to eligible entities that award financial assistance to eligible households as well as provide housing stability services. ERA grantees may provide assistance to eligible households directly or to landlords and utility providers on behalf of eligible households. The County received an award from the U.S. Department of the Treasury to provide financial assistance to eligible households, including payment of rent, utilities and other housing stability services. During fiscal year 2022, the County spent $229,617 of this award. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. To comply with reporting requirements, the County must submit to the Treasury monthly and quarterly ERA 1 and ERA 2 reports (special reporting 1505-0266 and 1505-0270, respectively). The monthly reports must identify key information such as the number of participating households the county provided ERA assistance of any kind to and the total amount of ERA funds the County expended for these households. The quarterly reports identify the total amount obligated by the County and total amount expended. Both reports are important because the Treasury uses the amounts expended and obligated to assess grantee eligibility for reallocation payments and to determine if the County is subject to involuntary recapture of funds to reallocate to other grantees or return to the grantor. Our audit found that the County’s internal controls were inadequate for ensuring it submitted the monthly and quarterly ERA reports and included accurate information. Specifically, the County did not submit three of the nine required monthly reports. Additionally, the County did not include the required accumulative expenditures and accumulated obligations in the final quarterly report. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition Due to staff turnover and technical issues in accessing the Treasurer’s portal, the County did not submit all the required monthly reports. Also, the County employee responsible for the program was new to the position and did not ensure the quarterly reports included all required information. Effect of Condition The U.S. Department of Treasury uses these reports to assess grantee eligibility for reallocation payments and to determine if the grantee is subject to involuntary recapture of funds to reallocate to other grantees or return to the grantor. Any inaccurate information in these monthly and quarterly reports limits the Treasury’s ability to decide reallocations, maintain transparency and fulfill its legal obligations. Since the County was unable to provide the data it used to prepare the reports, it cannot demonstrate the accuracy of the information reported. Recommendation We recommend that the County implement internal controls to ensure it submits all monthly reports and accurate quarterly reports. County’s Response Auditor’s Remarks Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, section 329, Monitoring and reporting program performance, describes the requirements for auditees to perform oversight of the operations of the federal award supported activities to ensure compliance with applicable federal requirements and performance expectations. The Consolidated Appropriations Act, 2021, title V, Banking, subtitle A, Emergency Rental Assistance, section 501(g), Reporting requirements, describes the required performance and financial data and frequency of reports for this federal program. Section 501(b) describes the reallocation requirements.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties Eligibility Material Weakness Reporting

Other Findings in this Audit

  • 556192 2022-002
    Material Weakness Repeat
  • 556193 2022-002
    Material Weakness Repeat
  • 556194 2022-002
    Material Weakness Repeat
  • 556195 2022-003
    Material Weakness
  • 1132634 2022-002
    Material Weakness Repeat
  • 1132635 2022-002
    Material Weakness Repeat
  • 1132636 2022-002
    Material Weakness Repeat
  • 1132637 2022-003
    Material Weakness
  • 1132638 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.023 Covid 19 - Emergency Rental Assistance Program $4.31M
21.027 Covid 19 - Coronavirus State and Local Fiscal Recovery Funds $4.27M
14.231 Emergency Solutions Grant Program $1.31M
93.563 Child Support Enforcement $453,319
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $120,446
93.959 Block Grants for Prevention and Treatment of Substance Abuse $110,914
16.575 Crime Victim Assistance $81,411
93.788 Opioid Str $68,652
16.839 Stop School Violence $63,817
21.019 Covid 19 - Coronavirus Relief Fund $62,020
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $58,988
14.267 Continuum of Care Program $46,464
21.032 Local Assistance and Tribal Consistency Fund $25,583
10.555 National School Lunch Program $22,610
16.751 Covid 19 - Edward Byrne Memorial Competitive Grant Program $18,155
20.205 Highway Planning and Construction $13,541
10.553 School Breakfast Program $13,331
97.012 Boating Safety Financial Assistance $12,174
20.616 National Priority Safety Programs $6,961
16.922 Equitable Sharing Program $1,820
16.034 Coronavirus Emergency Supplemental Funding Program $1,342
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $820
93.658 Foster Care Title IV-E $318