Finding Text
The City?s internal controls were inadequate for ensuring compliance with federal reporting requirements. Assistance Listing Number and Title: 14.218 ? Community Development Block Grants/Entitlement Grants 14.218 ? COVID 19 ? Community Development Block Grants/Entitlement Grants Federal Grantor Name: U.S. Department of Housing and Urban Development Federal Award/Contract Number: B-16-MC-53-0007 B-17-MC-53-0007 B-20-MC-53-0007 COVID-19 B-20-MW-53-0007 B-21-MC-53-0007 B-22-MC-53-0007 Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Description of Condition The City spent $4,671,311 in Community Development Block Grants/Entitlement Grants (CDBG) in 2022. Of that amount, the City passed through $2,176,389 to four subrecipients. The purpose of the CDBG program is to help provide decent and affordable housing, particularly for people with moderate, low and very low incomes. Funds also help recipients implement strategies for achieving an adequate supply of decent housing and providing a suitable living environment and expanded economic opportunities for people with low incomes. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. To comply with federal reporting requirements, the City must submit certain financial and special reports to the U.S. Department of Housing and Urban Development (HUD). For the CDBG program, this includes the Cash on Hand Quarterly Report (PR29) and reports required under the Federal Funding Accountability and Transparency Act (FFATA). Cash on Hand Quarterly Report The City?s Cash on Hand Quarterly Reports (PR29 and PR29-CV) must include accurate information relating to cash on hand, program income and revolving funds. We found the City?s internal controls were ineffective for ensuring staff submitted the required reports in compliance with federal reporting requirements. We found the City did not complete eight required Cash on Hand Quarterly Reports (four PR29 and four PR29-CV) during the audit period. Therefore, none of the grantees? information was submitted to their awarding agency. FFATA Reporting The FFATA requires direct recipients that make first-tier subawards of $30,000 or more to report them in the FFATA Subaward Reporting System (FSRS). The City must report subawards by the end of the month following the month in which it made the subaward or subaward amendment. We found the City?s internal controls were ineffective for ensuring it reported four subawards obligated in 2022 in the FSRS, as federal regulations require. We consider these internal control deficiencies to be material weaknesses, which led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition The City staff responsible for submitting these reports did not have the necessary training or a clear understanding of the reporting requirements. Effect of Condition Cash on Hand Quarterly Report The PR29 and PR29-CV reports document a grantee?s compliance with the low- and moderate-income benefit requirement, the amount obligated and expended for public services, and the amount obligated for planning and administration for the selected program year. The reports include funding data that HUD then reports to Congress and uses to monitor grantees. Failing to submit accurate and complete information to HUD diminishes the federal government?s ability to ensure proper monitoring of grantees. FFATA Failing to submit the required reports on time with accurate information diminishes the federal government?s ability to ensure accountability and transparency of federal spending. Below is a summary of the missing reports we identified. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 4 4 0 $0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $2,176,389 $2,176,389 0 $0 0 Recommendation We recommend the City establish and follow internal controls over federal reporting requirements to ensure it submits accurate Cash on Hand Quarterly Reports and FFATA reports by the federal deadlines. City?s Response The City takes their responsibility for creating internal controls to ensure compliance with federal requirements in the highest regard. Management is committed to ensuring the City has internal controls and procedures in place designed to ensure that it complies with all requirements governing the administration of federal grant programs. To achieve this, the City will take the following action: The City will clarify roles and responsibilities for the departments that have a role in federal reporting requirements. The City will also establish internal controls and ensure staff have a clear understanding of the reporting requirements. Auditor?s Remarks We thank the City for its response and consideration in this matter, as well as the steps it is taking to address this issue. We will review the status of the City?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, section 328, Financial reporting, establishes requirements for recipients? financial information. Title 2 CFR Part 170, Reporting Subaward and Executive Compensation Information, section 200, Federal Awarding Agency Reporting Requirements, establishes the Federal Funding Accountability and Transparency Act (FFATA) requirements of reporting the subward information through the FFATA Subaward Reporting System (FSRS).