Finding Text
BCC 2022-004 ? PERIOD OF PERFORMANCE ? COMPLIANCE AND CONTROLS FEDERAL AGENCY: U.S. DEPARTMENT OF HOMELAND SECURITY, FEDERAL EMERGENCY MANAGEMENT AGENCY PASS-THROUGH ENTITY: FLORIDA EXECUTIVE OFFICE OF GOVERNOR, DIVISION OF EMERGENCY MANAGEMENT PROGRAM: DISASTER GRANTS-PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS), ALN 97.036 AWARD YEAR: DR 4177 ? 2014 FINDING TYPE: MATERIAL WEAKNESS; MATERIAL NONCOMPLIANCE CRITERIA: 2 CFR 200.303(a) of the Uniform Guidance requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, under other Uniform Guidance requirements, the County may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Each individual project under this program has a specified work deadline, which may be extended at the discretion of FEMA. CONDITION: Two projects were tested for compliance with this requirement, including all expenditures during fiscal year 2022 for these projects. The two projects make up the entire population of projects during fiscal year 2022. Both projects have an approved extension of the work deadline (period of performance) through March 31, 2022. However, the County incurred costs for work performed after this extension period. CAUSE: The County is in the process of obtaining approval for an extension of the work deadline for these projects from FEMA. The County has continued to have work performed on the projects in the meantime. EFFECT: If an extension of the work deadline for the projects is not approved, the costs would be ineligible for reimbursement and the County will have reported an incorrect amount of expenditures of federal awards. QUESTIONED COSTS: $462,104. These were determined by totaling costs incurred outside the period of performance based on work dates in the invoices. For any invoices that covered a specified period but costs were not attached to specific dates, the costs were allocated evenly over the period. RECOMMENDATION: We recommend the County obtain approval of an extension of the work deadline for projects prior to incurring costs after the currently approved deadline. VIEWS OF RESPONSIBLE OFFICIALS: See Management?s Response and Corrective Action Plan beginning page 125.