Finding 574140 (2024-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-08-21
Audit: 364708
Organization: Town of Babylon (NY)

AI Summary

  • Core Issue: Reports were submitted late, missing deadlines by up to 11 days, which violates federal grant reporting requirements.
  • Impacted Requirements: Compliance with U.S. Treasury guidelines mandates timely submission of quarterly reports within 30 days post-quarter.
  • Recommended Follow-Up: Implement stronger internal controls, designate a compliance officer, create a reporting calendar with reminders, and ensure staff training on reporting requirements.

Finding Text

2024-002 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing #21.027 – Reporting Condition The auditee submitted one or more required quarterly Project and Expenditure Reports to the U.S. Department of the Treasury after the established submission deadlines. For example, the report for the quarter ending December 31, 2024, was submitted on February 11, 2025, which was 11 days past the deadline of January 31, 2025. Criteria According to the U.S. Department of the Treasury’s Compliance and Reporting Guidance for State and Local Fiscal Recovery Funds (most recently updated April 29, 2025), recipients are required to submit quarterly Project and Expenditure Reports no later than 30 days after the end of each calendar quarter. Timely submission is required to maintain compliance with federal grant reporting requirements under 2 CFR §200.328(b)(1), which states that recipients must submit performance reports by the required due dates. Cause The delay in submitting the reports was primarily due to confusion on how to report obligated amounts in the Project and Expenditure Report. Specifically uncertain about how to report obligations in accordance with Treasury guidance, which delayed the completion and submission of the report. Effect Late submission of required federal reports may result in noncompliance with grant terms and conditions, increased scrutiny from the granting agency, and potential impacts on future funding. Furthermore, untimely reporting can hinder transparency and federal oversight of how SLFRF funds are being used. Questioned Costs None Recommendation We recommend that management implement stronger internal controls to ensure timely preparation and submission of all required federal reports. This may include designating a responsible official for compliance tracking, developing a calendar of reporting deadlines with automated reminders, and performing periodic reviews to ensure submission timelines are met. Management should also ensure that staff responsible for federal reporting are adequately trained on applicable requirements and deadlines. View of Responsible Official The Town will establish policies and procedures to comply with SLFRF reporting and guidelines to ensure timely and accurate reporting.

Corrective Action Plan

The Town acknowledges the finding related to the delayed submission of the 4th Quarter 2024 ARPA report and concurs with the auditor’s recommendation. While the Town ultimately recognizes its responsibility to meet the filing deadlines for all federal reporting, the Town has instituted efforts to mitigate the reporting lapse since the oversight. To prevent recurrence, the Town has implemented the following corrective actions: 1. Formal Reporting Calendar: A centralized ARPA reporting calendar has been created. This calendar will include internal deadlines at least 14 days in advance of federally mandated submission dates. 2. Assigned Reporting Officer: A designated ARPA Reporting Officer has been appointed, responsible for coordinating all necessary documentation and submissions related to ARPA funding. 3. Pre-Submission Review Process: A new protocol has been established requiring internal review and sign-off from both the Comptroller and the Town Supervisor’s designee no less than one week prior to each deadline. 4. Ongoing Training and Coordination: The Town will continue to work closely with its auditors and legal counsel to remain current on federal guidance, ensure continued compliance with Uniform Guidance standards, and maintain internal staff awareness of applicable obligations under ARPA. We believe these measures will ensure timely and accurate reporting for all future quarters and strengthen our internal compliance infrastructure.

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 574139 2024-001
    Significant Deficiency
  • 1150581 2024-001
    Significant Deficiency
  • 1150582 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $17.91M
21.027 Coronavirus State and Local Fiscal Recovery Funds $5.20M
66.202 Congressionally Mandated Projects $1.00M
14.239 Home Investment Partnerships Program $385,576
14.218 Community Development Block Grants/entitlement Grants $331,632
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $177,092
14.896 Family Self-Sufficiency Program $60,532
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $44,996
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $23,877
93.053 Nutrition Services Incentive Program $20,171
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $7,372
15.616 Clean Vessel Act $6,000