FAC Explorer

Finding 589512 (2022-011)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-09-27
Audit: 17407
Organization: City and County of Denver (CO)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: Discrepancies were found in three out of eight reports, indicating ineffective supervisory controls over reporting.
  • Impacted Requirements: Compliance with Uniform Guidance and ERA Reporting Guidance was not met, risking incorrect information reported to Treasury.
  • Recommended Follow-Up: Implement a reporting checklist and ensure documentation is reviewed and filed for all submitted reports.

Finding Text

Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. ERA Reporting Guidance v 3.4 identifies monthly reports and quarterly reports required to be submitted for the Emergency Rental Assistance Program (ERAP). Key line items for these reports are outlined within the Compliance Supplement and include for monthly reports- (1) total number of participating households that received ERAP assistance of any kind; (2) total amount of ERAP funds expended by the ERAP grantee to or for participating households and for quarterly reports- (1) the cumulative amount obligated by the grantee and (2) the cumulative amount expended by the grantee. ERA Reporting Guidance v 3.4 defines an obligation as ??a commitment to pay a third party with ERA award proceeds based on a contract, subaward, direct payment, or other arrangement.? U.S Department of the Treasury Emergency Rental Assistance Under the Consolidated Appropriations Act, 2021 Reallocation Guidance (Reallocation Guidance), issued October 4, 2021, and updated September 6, 2022, states ?Grantees are encouraged to partner with local nonprofit organizations and governmental agencies to expedite the obligation process and delivery of assistance to eligible households. However, grantees may not use subrecipient agreements with these entities to avoid meeting the statutory obligation deadline, and funds will not be considered obligated based solely on the fact they are subject to an agreement that provides for another entity to administer assistance on the grantee?s behalf.? The Reallocation Guidance further states Treasury will conduct a final assessment of each grantee?s Expenditure Ratio based on data reported through March 31, 2022. At that time, any unobligated ERA1 funds may be determined to be excess funds. Condition: During our testing of reporting, we noted for three of the eight reports, discrepancies between amounts included in the reports and relevant supporting documentation. Cause: The Department?s supervisory and review control was not operating effectively to ensure that all key line items reported in the monthly and quarterly reports were properly supported. Effect or Potential Effect: Incorrect information, especially pertaining to the reporting of obligations, was reported to Treasury, which could have affected decisions pertaining to unobligated funds existing as of March 31, 2022. Questioned Costs: None Context: We tested a sample of eight reports from a population of 20. We identified exceptions in three of the reports tested. The exceptions by report are as follows: **ERA2 Quarter 3 Report- Current quarter obligations in the amount of $4,492,359, which were key in determining cumulative obligations to date, were traced to supporting documentation. However, such amounts were different by $58,019. **ERA1 Quarter 1 Report- (1) The cumulative amount of award obligated as of the end of the reporting period was stated at the full amount of the grant award ($21,884,992). This appeared to be overstated based on the Reallocation Guidance from Treasury. The exact amount of what cumulative obligations should have been was not determinable. HOST corrected the practice on future quarterly reports. **March 2022 ERA1 Monthly Report- Data did not trace back to supporting schedules. Total rental payments to individuals were reported as $1,565,364 with 275 households. Supporting schedules showed $1,562,973 with 274 households. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: N/A Recommendation: Documentation should be kept for all numbers on reports submitted and review of reports submitted should contain evidence that someone reviewed and traced key report line items to supporting documentation. Such evidence should be filed with each report (i.e., signed checklist of what was done prior to reports being submitted or e-mail approval). Views of Responsible Officials: The City agrees with the finding. HOST will establish a reporting checklist and an e-mail approval with evidence of the review of documentation supporting the numbers being submitted in reports. For additional information, see the City?s separate report for planned corrective actions.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 13044 2022-005
    Material Weakness Repeat
  • 13045 2022-006
    Material Weakness
  • 13046 2022-009
    Material Weakness Repeat
  • 13047 2022-008
    Significant Deficiency Repeat
  • 13048 2022-018
    Significant Deficiency
  • 13049 2022-006
    Material Weakness
  • 13050 2022-008
    Significant Deficiency Repeat
  • 13051 2022-018
    Significant Deficiency
  • 13052 2022-010
    Significant Deficiency
  • 13053 2022-015
    Significant Deficiency Repeat
  • 13054 2022-018
    Significant Deficiency
  • 13055 2022-010
    Significant Deficiency
  • 13056 2022-015
    Significant Deficiency Repeat
  • 13057 2022-018
    Significant Deficiency
  • 13058 2022-016
    Significant Deficiency
  • 13059 2022-018
    Significant Deficiency
  • 13060 2022-014
    Significant Deficiency
  • 13061 2022-018
    Significant Deficiency
  • 13062 2022-014
    Significant Deficiency
  • 13063 2022-018
    Significant Deficiency
  • 13064 2022-018
    Significant Deficiency
  • 13065 2022-018
    Significant Deficiency
  • 13066 2022-018
    Material Weakness
  • 13067 2022-018
    Significant Deficiency
  • 13068 2022-018
    Significant Deficiency
  • 13069 2022-018
    Significant Deficiency
  • 13070 2022-011
    Significant Deficiency
  • 13071 2022-013
    Significant Deficiency
  • 13072 2022-018
    Significant Deficiency
  • 13073 2022-012
    Material Weakness
  • 13074 2022-018
    Significant Deficiency
  • 13075 2022-012
    Material Weakness
  • 13076 2022-018
    Significant Deficiency
  • 13077 2022-010
    Significant Deficiency
  • 13078 2022-015
    Significant Deficiency Repeat
  • 13079 2022-018
    Significant Deficiency
  • 13080 2022-015
    Significant Deficiency Repeat
  • 13081 2022-007
    Significant Deficiency
  • 13082 2022-012
    Material Weakness
  • 13083 2022-018
    Significant Deficiency
  • 13084 2022-010
    Significant Deficiency
  • 13085 2022-015
    Significant Deficiency Repeat
  • 13086 2022-018
    Significant Deficiency
  • 13087 2022-010
    Significant Deficiency
  • 13088 2022-015
    Significant Deficiency Repeat
  • 13089 2022-018
    Significant Deficiency
  • 13090 2022-010
    Significant Deficiency
  • 13091 2022-015
    Significant Deficiency Repeat
  • 13092 2022-018
    Significant Deficiency
  • 13093 2022-010
    Significant Deficiency
  • 13094 2022-015
    Significant Deficiency Repeat
  • 13095 2022-018
    Significant Deficiency
  • 13096 2022-010
    Significant Deficiency
  • 13097 2022-015
    Significant Deficiency Repeat
  • 13098 2022-018
    Significant Deficiency
  • 13099 2022-017
    Significant Deficiency Repeat
  • 13100 2022-018
    Significant Deficiency
  • 589486 2022-005
    Material Weakness Repeat
  • 589487 2022-006
    Material Weakness
  • 589488 2022-009
    Material Weakness Repeat
  • 589489 2022-008
    Significant Deficiency Repeat
  • 589490 2022-018
    Significant Deficiency
  • 589491 2022-006
    Material Weakness
  • 589492 2022-008
    Significant Deficiency Repeat
  • 589493 2022-018
    Significant Deficiency
  • 589494 2022-010
    Significant Deficiency
  • 589495 2022-015
    Significant Deficiency Repeat
  • 589496 2022-018
    Significant Deficiency
  • 589497 2022-010
    Significant Deficiency
  • 589498 2022-015
    Significant Deficiency Repeat
  • 589499 2022-018
    Significant Deficiency
  • 589500 2022-016
    Significant Deficiency
  • 589501 2022-018
    Significant Deficiency
  • 589502 2022-014
    Significant Deficiency
  • 589503 2022-018
    Significant Deficiency
  • 589504 2022-014
    Significant Deficiency
  • 589505 2022-018
    Significant Deficiency
  • 589506 2022-018
    Significant Deficiency
  • 589507 2022-018
    Significant Deficiency
  • 589508 2022-018
    Material Weakness
  • 589509 2022-018
    Significant Deficiency
  • 589510 2022-018
    Significant Deficiency
  • 589511 2022-018
    Significant Deficiency
  • 589513 2022-013
    Significant Deficiency
  • 589514 2022-018
    Significant Deficiency
  • 589515 2022-012
    Material Weakness
  • 589516 2022-018
    Significant Deficiency
  • 589517 2022-012
    Material Weakness
  • 589518 2022-018
    Significant Deficiency
  • 589519 2022-010
    Significant Deficiency
  • 589520 2022-015
    Significant Deficiency Repeat
  • 589521 2022-018
    Significant Deficiency
  • 589522 2022-015
    Significant Deficiency Repeat
  • 589523 2022-007
    Significant Deficiency
  • 589524 2022-012
    Material Weakness
  • 589525 2022-018
    Significant Deficiency
  • 589526 2022-010
    Significant Deficiency
  • 589527 2022-015
    Significant Deficiency Repeat
  • 589528 2022-018
    Significant Deficiency
  • 589529 2022-010
    Significant Deficiency
  • 589530 2022-015
    Significant Deficiency Repeat
  • 589531 2022-018
    Significant Deficiency
  • 589532 2022-010
    Significant Deficiency
  • 589533 2022-015
    Significant Deficiency Repeat
  • 589534 2022-018
    Significant Deficiency
  • 589535 2022-010
    Significant Deficiency
  • 589536 2022-015
    Significant Deficiency Repeat
  • 589537 2022-018
    Significant Deficiency
  • 589538 2022-010
    Significant Deficiency
  • 589539 2022-015
    Significant Deficiency Repeat
  • 589540 2022-018
    Significant Deficiency
  • 589541 2022-017
    Significant Deficiency Repeat
  • 589542 2022-018
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance for Needy Families $20.71M
21.023 Emergency Rental Assistance Program $19.69M
20.106 Airport Improvement Program $16.78M
93.575 Child Care and Development Block Grant (ccdbg) $13.92M
93.778 Medical Assistance Program $13.54M
93.600 Head Start/ Covid-19 Head Start $12.98M
93.658 Foster Care_title IV-E $11.10M
93.563 Child Support Enforcement $9.89M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $9.31M
14.218 Community Development Block Grants $8.23M
14.231 Emergency Solutions Grant Program $7.23M
93.914 Hiv Emergency Relief Project Grants $7.14M
20.205 Highway Planning and Construction $6.55M
21.027 Coronavirus State and Local Fiscal Recovery Funds $4.13M
14.239 Home Investment Partnerships Program $4.10M
93.659 Adoption Assistance $3.78M
93.667 Social Services Block Grant $3.68M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc)/ Covid-19- Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $2.73M
17.268 H-1b Job Training Grants $2.29M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $2.25M
97.106 Securing the Cities Program $2.24M
97.067 Homeland Security Grant Program $2.23M
14.267 Continuum of Care Program $1.96M
17.258 Wia Adult Program $1.77M
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.75M
14.218 Community Development Block Grants/entitlement Grants $1.72M
17.259 Wia Youth Activities $1.41M
93.569 Community Services Block Grant/ Covid-19- Community Services Block Grant $1.25M
97.044 Assistance to Firefighters Grant $1.07M
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $1.07M
20.200 Highway Research and Development Program $1.05M
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $949,501
17.207 Employment Service/wagner-Peyser Funded Activities $852,416
93.268 Covid-19 - Immunization Cooperative Agreements $743,210
16.922 Equitable Sharing Program $722,896
93.069 Public Health Emergency Preparedness $718,191
93.994 Maternal and Child Health Services Block Grant to the States $680,843
17.278 Wia Dislocated Worker Formula Grants $675,323
95.001 High Intensity Drug Trafficking Areas Program $604,180
16.575 Crime Victim Assistance $591,833
11.307 Economic Adjustment Assistance $553,992
16.741 Dna Backlog Reduction Program $544,713
93.645 Stephanie Tubbs Jones Child Welfare Services Program $531,202
45.024 Covid-19 - Promotion of the Arts Grants to Organizations and Individuals $500,000
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood/ Covid-19 - John H. Chafee Foster Care Program for Successful Transition to Adulthood $422,536
10.664 Cooperative Forestry Assistance $339,235
93.556 Marylee Allen Promoting Safe and Stable Families Program $338,161
16.738 Edward Byrne Memorial Justice Assistance Grant Program $308,460
10.551 Supplemental Nutrition Assistance Program (snap) $282,934
17.277 Covid-19 - Wioa National Dislocated Worker Grants $276,509
16.817 Byrne Criminal Justice Innovation Program $256,892
20.600 State and Community Highway Safety $255,614
93.090 Guardianship Assistance $251,889
10.558 Child and Adult Care Food Program (cacfp) $247,343
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $226,826
17.270 Reentry Employment Opportunities $201,650
93.136 Injury Prevention and Control Research and State and Community Based Programs $201,553
16.320 Services for Trafficking Victims $193,666
10.555 Covid-19- National School Lunch Program $176,196
16.576 Crime Victim Compensation $170,000
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $161,490
16.034 Covid-19- Coronavirus Emergency Supplemental Funding Program $155,747
14.241 Housing Opportunities for Persons with Aids $147,590
16.588 Violence Against Women Formula Grants $128,816
17.285 Apprenticeship USA Grants $124,128
17.245 Trade Adjustment Assistance $106,993
17.225 Unemployment Insurance $101,500
16.582 Crime Victim Assistance/discretionary Grants $99,261
97.042 Emergency Management Performance Grants $98,842
45.313 Laura Bush 21st Century Librarian Program $96,227
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $94,876
45.149 Promotion of the Humanities Division of Preservation and Access $71,079
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $60,646
16.825 Smart Prosecution Initiative $58,326
16.560 National Institute of Justice Research $58,152
93.568 Low-Income Home Energy Assistance $55,045
84.425 Covid-19 Education Stabilization Fund $54,180
21.017 Social Impact Partnerships to Pay for Results Act $52,775
93.317 Emerging Infections Programs $46,692
93.747 Covid-19 - Elder Abuse Prevention Interventions Program $46,566
16.036 Prosecuting Cold Cases Using Dna $45,993
16.609 Project Safe Neighborhoods $43,915
93.940 Hiv Prevention Activities Health Department Based $39,175
93.670 Child Abuse and Neglect Discretionary Activities $38,402
93.354 Covid-19 - Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $38,312
45.309 Museum Grants for African American History and Culture $37,320
97.047 Building Resilient Infrastructure and Communities (bric) $31,324
16.710 Public Safety Partnership and Community Policing Grants $26,091
20.507 Federal Transit Formula Grants $22,276
20.500 Federal Transit Capital Investment Grants $12,591
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $11,739
66.605 Performance Partnership Grants $8,026
17.801 Jobs for Veterans State Grants $7,644
66.808 Solid Waste Management Assistance Grants $3,800
93.648 Child Welfare Research Training Or Demonstration $2,991
15.605 Sport Fish Restoration $503
66.818 Brownfields Multipurtpose, Assessment. Revolving Loan Fund, and Cleanup Cooperative Agreements $211
84.196 Education for Homeless Children and Youth $77
21.019 Coronavirus Relief Fund $-3,763