Finding 602667 (2022-101)

Assistance Listings number and name: 10.691 Good Neighbor Authority Award numbers and year: 22-GN-11030400-027 January 14, 2022 through January 12, 2027 Federal agency: U.S. Department of Agriculture (UDSA) Compliance requirements: Period of Performance Questioned costs: $42,555 Condition?Contrary to federal regulation and the County?s grant award with the U.S. Department of Agriculture (USDA), the County?s Flood Control District spent $42,555 on unallowable purchases that it requested and received reimbursement for as part of the program?s $1.4 million total expenditures. Specifically, for 1 of 2 transactions tested, the District spent $42,555 on construction-planning services for repairing flood damage before the time period the costs were allowed to be incurred and did not receive preapproval from the federal agency, as required. Effect?The USDA may require the County to reimburse the $42,555 in unallowable costs with other County monies and either require the County to return the monies or spend them on other allowable costs before the grant expiration date of January 12, 2027.1 Cause?Despite the County?s grant award with USDA specifying the period of performance requirements, the County?s existing polices to review reimbursement requests did not require verifying that preapprovals were obtained from the federal agency when costs were incurred before the grant award term?s start date. Criteria?Federal regulation and the County?s grant award terms and conditions with USDA allow the Department to charge only allowable costs incurred during the performance period, or January 14, 2022 through January 12, 2027, and require any costs incurred before the start date to be preapproved by the federal agency (2 Code of Federal Regulations [CFR] ?200.458 and USDA grant award terms ?AA). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve existing policies and procedures for federal grants by requiring the reviewer to verify that preapprovals were obtained from the federal agency when costs were incurred before the award term?s start date. 2. Request and obtain preapproval from the federal agency for all costs incurred outside the award term?s performance period. 3. Work with the U.S Department of Agriculture to resolve the $42,555 of program monies the District spent in violation of its federal award terms, which may involve returning monies to the federal agency.1 The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the County, takes appropriate and timely corrective action (2 CFR ?200.513[c]). Further, it requires that federal awarding agencies? management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR ?200.521).