Finding 606604 (2022-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-09-19
Audit: 30878
Organization: City of Rome, New York (NY)

AI Summary

  • Core Issue: There were multiple compliance failures in FFATA reporting for subawards and subcontracts, including untimely submissions and incorrect information.
  • Impacted Requirements: The City must report subawards and subcontracts accurately and on time in the FSRS portal, adhering to the Transparency Act guidelines.
  • Recommended Follow-Up: Ensure that grant administrators are aware of reporting triggers and deadlines, and improve communication between departments to avoid delays in FFATA submissions.

Finding Text

I. FINDINGS?FINANCIAL STATEMENT AUDIT None II. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2022-01 Reporting Under Federal Funding Accountability and Transparency Act (FFATA) Compliance Requirement: Reporting U.S. Department of Housing and Urban Development CDBG ? Entitlement Grants Cluster AL# 14.218 Community Development Block Grant ? Entitlement Grant Condition: During our test of FFATA submissions we tested 2 sub grants and 4 contracts and noted the following: Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 2 0 1 1 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $138,490 $0 $138,490 $0 $0 Transactions Tested Subcontract not reported Report not timely Subcontract amount incorrect Subcontract missing key elements 4 0 1 1 0 Dollar Amount of Tested Transactions Subcontract not reported Report not timely Subcontract amount incorrect Subcontract missing key elements $1,162,059 $677,344 $484,715 $0 $0 Criteria: First-tier awards that are subject to reporting under the Transparency Act based on (a) the date of the award and (b) the amount of the obligating action for subawards and subcontracts including modifications. If a subaward/subcontract is subject to reporting, the City is required to enter the award/contract information in the FSRS portal. Information entered should be supported by source documents such as signed subaward/contract agreements and if applicable modifications or amendments. The action needs to be reported in FSRS portal no later than the last day of the month following the month in which the subaward (contract)/subaward (contract) amendment obligation was made. Cause: Unknown. Effect or Potential Effect: Noncompliance with FFATA reporting including timeliness and accuracy of information submitted. Known Questioned Costs: None noted. Context: First-tier subawards/subcontracts. Repeat Finding: No Recommendation: It is recommended that the timeliness and accuracy requirements in submitting the FFATA reporting should be adhered to. Specifically, if a department receives a direct federal grant award and in turn makes first-tier subawards/subcontracts, the person responsible for the grant administration should be alerted to the triggering events that could result in a need for the FFATA reporting. This includes any amendments to the sub award/contract agreement. 78 II. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS (Continued) 2022-01 Reporting Under Federal Funding Accountability and Transparency Act (FFATA) (Continued) Views of Responsible Officials: The City acknowledges the deficiencies found on page 77 of the audit concerning timely filing of Federal Funding Accountability and Transparency Act (FFATA). The Finance Clerk in the Treasurer?s Office prepares the filing on behalf of the City Departments. In this case of deficiency, FFATA reporting was being transmitted from the CED department to the Finance Clerk at the time of Purchase Order Request and not the date of contract execution. The lag between contract executions and Purchase Order Requests has been in some instances longer than the reporting period of contracting, which is the end of the month following the month in which the prime awardee awards any sub-awards equal to or greater than $30,000, and thus reporting has been untimely, although ultimately reported on.

Categories

Reporting Subrecipient Monitoring

Other Findings in this Audit

  • 30162 2022-001
    Significant Deficiency
  • 30163 2022-001
    Significant Deficiency
  • 606605 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.019 Coronavirus Relief Fund $2.36M
20.205 Highway Planning and Construction $602,402
14.218 Community Development Block Grants/entitlement Grants $531,739
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $39,127
16.554 National Criminal History Improvement Program (nchip) $15,000
20.600 State and Community Highway Safety $9,874
16.922 Equitable Sharing Program $2,981
20.616 National Priority Safety Programs $356