Finding Text
Finding 2022-003 ? Reporting ? Compliance and Control Finding Federal Award. No. 21.023 Emergency Rental Assistance Program ? COVID 19 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Missouri Department of Economic Development Criteria Or Specific Requirement: All Emergency Rental Assistance (ERA) grantees must submit monthly and quarterly reports. Monthly reports capture details specific to that month while quarterly reports contain several cumulative fields covering all activity from the date of the grant award through the quarter close. These reports provide financial and performance data regarding grantee administration of their ERA projects and capture program design in addition to program status data elements. Quarterly reports are intended to capture standard financial and performance data, as well as detailed information on qualifying direct and indirect expenditures pursuant to the government-wide Federal Funding Accountability and Transparency Act (FFATA) reporting requirements and in accordance with Section 15011 of the Coronavirus Aid, Relief, and Economic Security Act, as amended and interpreted in the U.S. Department of Treasury?s reporting and compliance guidance on Treasury.gov. Condition: In our nonstatistical sample, we noted four monthly reports and one quarterly report of eight tested in which we were unable to agree identified ?Key Line Items? to the general ledger. For the monthly reports, the key line item noted was the ?Total amount of ERA funds expended by the ERA grantee to or for participating households on behalf of eligible households? line. For the quarterly report, the key line items were ?the cumulative amount obligated by the grantee? and ?the cumulative amount expended by the grantee?. Records supporting obligated amounts were not retained from the application database. The Commission?s general ledger accounts, which can include voided transactions, need to be reconciled to the application program details file. The process of reconciling and retaining the information used to create these reports was not in place throughout the entirety of the current year. Cause: Due to timing and staffing constraints, these reports were created from live files which were not reconciled with the general ledger prior to submission of the reports. Additionally, the live files in which the report were created were not retained by the Commission as supporting documentation for the amounts included in the reports submitted to the U.S. Treasury. Effect: The numbers reported to U.S. Treasury are not substantiated by supporting documentation such as a reconciliation, the general ledger or the live files that include program data. Questioned Costs: None Context: In our nonstatistical sample, we noted four monthly reports and one quarterly report of eight tested in which we were unable to agree identified ?Key Line Items? to the general ledger. Identification As A Repeat Finding: Not a repeat finding. Recommendation: The Commission should complete and retain reconciliations between the live program details file and the general ledger to support the amounts reported to U.S. Treasury. Views Of Responsible Officials: In order to navigate the required Department of Treasury reporting and to ensure that all reports reflect clear and appropriate information, staff has implemented many changes to process. To address staffing limitations, the Community Programs Processes Department was created in the fall of 2021 to aid in the reconciliation and financial tracking processes. In the early part of 2022, the Data and Analytics Department was officially formed to expand reporting capacity. New processes, in response to known limitations and timing restraints, have been developed to ensure adequate record keeping. Regular weekly meetings have been established between the Community Programs Processes Department, the Data and Analytics Department, and the Division Director to improve the coordination between all parties prior to the reporting deadlines. Additionally, where exceptions or changes must be made to reporting processes due to technical deficiencies or changes to guidance, processes have been established for clear communication and approval. Finally, as part of the regular coordination meetings, a debriefing of the reporting process occurs post submission so that improvements to the process may take place as needed. Anticipated Completion Date: The Commission developed new departments and added additional staffing in fall 2021 and early 2022. New processes for report completion, submission, and record keeping were developed in the late spring of 2022 and regular communication and process improvement are ongoing. The Commission expects to complete implementation of procedures and to document ERA report reconciliations with the general ledger during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs