Finding 578515 (2022-001)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-11-17
Audit: 3605
Organization: Bellingham, City of (WA)

AI Summary

  • Core Issue: The City lacked effective internal controls for complying with federal FFATA reporting requirements, leading to material noncompliance.
  • Impacted Requirements: The City failed to submit FFATA reports for seven subawards over $30,000, violating federal regulations.
  • Recommended Follow-Up: Strengthen internal controls to ensure timely preparation and submission of FFATA reports, with regular verification by responsible staff.

Finding Text

2022-001 The City did not have adequate internal controls for ensuring compliance with federal reporting requirements. Assistance Listing Number and Title: 14.218 – COVID-19 – Community Development Block Grant/Entitlement Grants 14.218 – Community Development Block Grants/Entitlement Grants Federal Grantor Name: U.S. Department of Housing and Urban Development (HUD) Federal Award/Contract Number: N/A Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The primary objective of the Community Development Block Grants/Entitlement Grants (CDBG) program is to help provide decent and affordable housing, particularly for people with moderate, low and very low incomes. Funds also help recipients implement strategies for achieving an adequate supply of decent housing and providing suitable living environments and expanded economic opportunities for people with low incomes. In 2022, the City spent $1,538,040 for its CDBG program. Of this amount, it passed $1,156,939 through to subrecipients. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring with effectiveness of established controls. The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients that make first-tier subawards of $30,000 or more to report them in the FFATA Subaward Reporting System (FSRS). The City has until the end of the month plus one additional month after obligating a subaward to fulfill this reporting requirement. Description of Condition We found the City’s internal controls were ineffective for ensuring compliance with FFATA reporting requirements. Specifically, the City made seven subawards in 2022 that exceeded $30,000, and it did not prepare or submit any FFATA reports for these subawards as required. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition City staff said they stopped using the FSRS.gov website when performance reporting systems changed. As a result, the City stopped receiving reminder notifications related to reporting deadlines. While FFATA reporting was included in the award agreements, staff in the responsible department were unaware the requirements still existed. Staff relied on the HUD platform and thought the City would not receive reimbursement if all the reporting requirements had not been met. Effect of Condition Failing to submit the required reports diminishes the federal government’s ability to ensure accountability and transparency of federal spending. The City has since submitted all FFATA reports applicable to the audit period. Below is a summary of the discrepancies we identified. Recommendation We recommend the City strengthen its internal controls to ensure it prepares and submits FFATA reports for all subawards subject to the requirement, as federal regulations require. City’s Response The City of Bellingham has corrected its oversight in failing to file FFATA reports related to Housing and Services Program federal funding, and all reports are now up to date. In the future, the City will ensure timely reporting with procedures in place for the responsible staff to report regularly and verify reporting is completed via email to the Housing and Services Program Manager. Auditor’s Remarks We appreciate the City’s commitment to resolve this finding and thank the City for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. 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 170, Reporting Subaward and Executive Compensation Information, establishes the Federal Funding Accountability and Transparency Act (FFATA) requirements of reporting the subaward information through the FFATA Subaward Reporting System (FSRS). 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.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 2073 2022-001
    Material Weakness
  • 2074 2022-001
    Material Weakness
  • 578516 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
15.614 Coastal Wetlands Planning, Protection and Restoration Program $980,000
14.218 Community Development Block Grants/entitlement Grants $870,642
21.027 Coronavirus State and Local Fiscal Recovery Funds $494,189
20.205 Highway Planning and Construction $362,571
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $346,526
21.019 Coronavirus Relief Fund $38,000
45.310 Grants to States $28,528
16.034 Coronavirus Emergency Supplemental Funding Program $23,623
97.042 Emergency Management Performance Grants $17,010
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $13,055
16.607 Bulletproof Vest Partnership Program $12,563
20.616 National Priority Safety Programs $11,943
15.904 Historic Preservation Fund Grants-in-Aid $10,000
16.588 Violence Against Women Formula Grants $9,943
16.738 Edward Byrne Memorial Justice Assistance Grant Program $2,501
84.033 Federal Work-Study Program $2,430
14.239 Home Investment Partnerships Program $700