Finding 586904 (2022-002)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2024-01-29
Audit: 14118
Organization: Whatcom County (WA)

AI Summary

  • Core Issue: The County lacked adequate internal controls to ensure compliance with federal reporting requirements for Disaster Grants, resulting in missing documentation for six out of eight quarterly reports.
  • Impacted Requirements: Federal regulations mandate timely submission of quarterly performance reports for large projects, which the County failed to meet, risking payment suspensions.
  • Recommended Follow-Up: Strengthen internal controls to maintain documentation of submitted reports and ensure compliance moving forward; monitor progress in the next audit.

Finding Text

2022-002 The County did not have adequate internal controls to ensurefor ensuring compliance with federal reporting requirements. Assistance Listing Number and Title: 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Grantor Name: Federal Emergency Management Agency, U.S. Department of Homeland Security Federal Award/Contract Number: FEMA-4539-DR-WA Pass-through Entity Name: WA Washington State Military Department Pass-through Award/Contract Number: D20-2069 Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Description of Condition The Disaster Grants- – Public Assistance (PA) program helps state, tribal and local governments pay for their response to and recovery from disasters. Following a pPresidential declaration of a major disaster or an emergency, the Federal Emergency Management Agency (FEMA) provides program funds supplemental federal disaster grant assistance for debris removal, emergency protective measures, and the restoration of disaster-damaged facilities owned by states, municipalities, tribes and certain private nonprofit organizations. In Washington, the PA program agency is the Military Department (Department). In 2022, the County spent $3,329,662 in program PA funds. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Federal regulations require the County to submit qThe County must comply with the following PA requirement for reporting: Quarterly Performance Reporting Quarterly progress reports are due from recipients onfor all open large projects within 30 days after the end of each calendar quarter. FEMA defines a large project as "“a project for which the final obligated (federal and nonfederal) amount is equal to or greater than the annually adjusted cost threshold for small project grants.” In 2022, the threshold for large projects was $139,800." The County is required to submit to the Department a quarterly report indicating the status of all their large projects. The reports shall status shall identify the costs incurred to date, the percentage of work completed, the anticipated completion date of the project and whether cost under runs or over runs are expected. In addition, the County should note in the comment field any challenges or issues associated with the project. Failure to submit a complete quarterly report within 15 days following the end of the quarter will result in suspension of all payments to the County until a complete quarterly report is received by the Department. The quarterly report will serve as the basis for any FEMA Office of Chief Financial Officer (OCFO) funds reduction. We found the County did not have a control in place have adequate controls in place and did not retain documentation showing it submitted six out of eight quarterly reports due to FEMA for two large projects in 2022 to the awarding agency. to ensure all quarterly performance reports were retained. As a result, we were unable to obtain sufficient appropriate audit evidence for six out of eight quarterly performance reports. We consider this control deficiency to be a material weakness that led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition The County staff said indicated it did submit they submitted hardprinted copies of all required quarterly performance reports to the Departmentawarding agencyFEMA. H, however, due to staff turnover due tobecause of staff turnover and the fact that printed reports were submittedreports being submitted in hard copy form, the County staff were was unable to locate an auditable copycopies of the reports submitted to demonstrate compliance . Effect of Condition By not retaining copies of the quarterly performance reports, management was unable to demonstrate the information the County reported was complete, and accurate, andthe Countyit submitted them within the required timeframe. FEMA The grantor may withhold payment if it does not receive quarterly reports are not received within 30 days. We did not identify any withheld payments. Recommendation We recommend the County strengthen internal controls to ensure for ensuring it maintains documentation showing it submitted required quarterly reports to the awarding agency FEMA when dueand supporting documentation are retained. County’s Response We agree the County failed to retain the first three quarters of this report. Accounting staff identified this issue at year end, prior to our audit and this finding. Procedures were updated in time for our 2022 4th quarter reporting and going forward. Auditor’s Remarks We thank the County for its commitment to resolving this issue. We will follow up on the status of this finding during our next 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 44 CFR section 206.204(f), Project Performance, states quarterly progress reports are required to be submitted for large projects. 2 CFR Part 200, Appendix XI, April 2022 Compliance Supplement, Part 4 – Agency Program Requirements, 97.036-Disaster Grants-Public Assistance (Presidentially Declared Disasters), Reporting section describes the requirement for grantees to prepare quarterly progress reports on all open large projects 30 days after the end of each calendar quarter.

Categories

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Allowable Costs / Cost Principles Material Weakness Reporting

Other Findings in this Audit

  • 10447 2022-001
    Material Weakness
  • 10448 2022-002
    Material Weakness
  • 10449 2022-002
    Material Weakness
  • 10450 2022-002
    Material Weakness
  • 10451 2022-002
    Material Weakness
  • 10452 2022-002
    Material Weakness
  • 10453 2022-002
    Material Weakness
  • 10454 2022-002
    Material Weakness
  • 10455 2022-002
    Material Weakness
  • 10456 2022-002
    Material Weakness
  • 10457 2022-002
    Material Weakness
  • 10458 2022-002
    Material Weakness
  • 10459 2022-002
    Material Weakness
  • 10460 2022-002
    Material Weakness
  • 10461 2022-002
    Material Weakness
  • 10462 2022-002
    Material Weakness
  • 10463 2022-002
    Material Weakness
  • 586889 2022-001
    Material Weakness
  • 586890 2022-002
    Material Weakness
  • 586891 2022-002
    Material Weakness
  • 586892 2022-002
    Material Weakness
  • 586893 2022-002
    Material Weakness
  • 586894 2022-002
    Material Weakness
  • 586895 2022-002
    Material Weakness
  • 586896 2022-002
    Material Weakness
  • 586897 2022-002
    Material Weakness
  • 586898 2022-002
    Material Weakness
  • 586899 2022-002
    Material Weakness
  • 586900 2022-002
    Material Weakness
  • 586901 2022-002
    Material Weakness
  • 586902 2022-002
    Material Weakness
  • 586903 2022-002
    Material Weakness
  • 586905 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Covid 19 - Coronavirus State and Local Fiscal Recovery Funds $8.67M
21.023 Covid 19 - Emergency Rental Assistance Program $2.91M
14.231 Emergency Solutions Grant Program $1.45M
93.323 Covid 19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $458,367
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $320,349
93.268 Covid 19 - Immunization Cooperative Agreements $290,704
93.959 Covid 19 - Block Grants for Prevention and Treatment of Substance Abuse $201,823
20.205 Highway Planning and Construction $146,783
16.738 Edward Byrne Memorial Justice Assistance Grant Program $78,781
90.404 2018 Hava Election Security Grants $72,761
93.563 Child Support Enforcement $69,127
97.067 Homeland Security Grant Program $64,953
16.751 Edward Byrne Memorial Competitive Grant Program $63,002
66.123 Geographic Programs - Puget Sound Action Agenda: Technical Investigations and Implementation Assistance Program $60,560
93.069 Public Health Emergency Preparedness $58,968
95.001 High Intensity Drug Trafficking Areas Program $56,000
66.456 National Estuary Program $37,000
17.278 Wioa Dislocated Worker Formula Grants $35,446
93.268 Immunization Cooperative Agreements $25,396
93.778 Medical Assistance Program $23,185
10.555 National School Lunch Program $21,364
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $20,828
16.575 Crime Victim Assistance $20,437
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $19,266
93.994 Maternal and Child Health Services Block Grant to the States $18,789
97.012 Boating Safety Financial Assistance $16,480
97.042 Emergency Management Performance Grants $12,794
97.047 Bric: Building Resilient Infrastructure and Communities $9,661
66.472 Beach Monitoring and Notification Program Implementation Grants $7,652
20.600 State and Community Highway Safety $5,105
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $4,255
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $3,985
16.833 National Sexual Assault Kit Initiative $2,990
10.665 Schools and Roads - Grants to States $1,578