Finding Text
Finding Reference Number: SA2022-007 Compliance with Grant Invoicing Requirements
AL Number: 20.205
Assistance Listing Title: Highway Planning and Construction Cluster
Federal Agency: Department of Transportation
Pass Through Entity: California Department of Transportation
Federal Award Identification Number: ATPL-5238(068)
Criteria: Section D of the grant award supplement requires that invoices be submitted at least once every 6 months and if no invoice is filed during that time, it requires that a “written explanation of the absence of activity along with target billing date and target billing amount” be submitted to the grantor.
Condition: During our testing of grant reimbursement requests filed for fiscal year 2022 expenditures, we noted that invoice 1 was filed on September 13, 2021, invoice 2 was filed on July 11, 2022, invoice 3 was filed on February 3, 2023 and invoice 4 was filed on January 25, 2024. The interval of billings was from 7 to 12 months, but City staff could not find documentation that the required communication for the lack of billing within six months had been made to the grantor.
Effect: The City is not in compliance with the billing interval or grantor communication requirements of Section D of the grant award agreement.
Cause: Due to staff turnover, City staff was unable to determine whether the communication had been made to the grantor.
Recommendation: The City should develop procedures to ensure grants passed through from the California Department of Transportation are invoiced every six months or communication is made to the grantor in accordance with the grant requirements. Documentation of the communication should be retained in the City’s grant files.
View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.