FAC Explorer

Finding 614017 (2022-007)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 32371
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: The Mayor's Office of Emergency Management (OEM) failed to properly evaluate the risk of noncompliance for subrecipients, impacting monitoring effectiveness.
  • Impacted Requirements: OEM did not follow 2 CFR 200.331 guidelines for risk assessment and monitoring, leading to inconsistencies in reported expenditures.
  • Recommended Follow-Up: Implement control procedures for risk assessments and ensure timely reconciliation of discrepancies in financial reporting with subrecipients.

Finding Text

Finding number: 2022 007 Federal agency: U.S. Department of Homeland Security Pass through agency: Massachusetts Executive Office of Public Safety & Security Program: Homeland Security Grant Program ALN #: 97.067 Award number: Boston FFY 19 UASI, Boston FFY 20 UASI, Boston FFY 21 UASI, Boston FFY 22 UASI, Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria According to 2 CFR 200.331 (b), a pass through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Also, according to 2 CFR 200.331 (d), a pass through entity must: ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. ? Follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on site reviews, and other means. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Based on our testwork, it was noted that the Mayor?s Office of Office of Emergency Management (OEM) did not perform a formal evaluation of each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring to be performed. Further, our review of program monitoring documentation for our sample of 4 of the population of 11 subrecipients indicated that, although OEM performed subrecipient monitoring in fiscal year 2022, OEM did not follow up with 2 out of 4 subrecipients as to why the amount of total program expenditures on the subrecipients? fiscal year 2021 Schedule of Expenditures of Federal Awards (SEFA) were different than total program expenditures reported to them by OEM. Cause This appears to be due to inadequate policies and procedures surrounding both the initial risk assessment of the subrecipients, as well as follow up with subrecipients when differences are noted between funding amounts reported to the subrecipient by OEM and amounts reported of the subrecipient?s SEFA. Effect OEM does not have adequate controls over evaluating each subrecipient?s risk of noncompliance for purposes of determining appropriate subrecipient monitoring, and ensuring that the total amount of expenditures reported on the subrecipient?s SEFA is consistent with grant funding provided by OEM to the subrecipient. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that OEM implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance for determining appropriate subrecipient monitoring, and to ensure that the total amount of expenditures reported on the subrecipient?s SEFA is consistent with grant funding provided by OEM to the subrecipient. View of Responsible Officials from the Auditee OEM will add an event to the departmental annual calendar on the first business day of the month of May of every year indicating that pre risk assessment forms for the upcoming fiscal year beginning on July 1st are to be sent out to subrecipients of federal funds. The addition of this even to the calendar will ensure that all appropriate Admin and Finance staff at OEM are aware of this annual requirement and follow up with subrecipients to receive completed pre risk assessments in advance of the new fiscal year. OEM?s Director of Admin and Finance will be the primary point of contact for pre risk assessment related inquiries from subrecipients, with the Assistant Deputy Chief of Administration serving as a backup point of contact. An event will also be added on the final business day of May each year to ensure that OEM staff follow up with subrecipients that were not responsive to the initial request. OEM will also institute a policy of requiring a written response following receipt of a SEFA letter from OEM detailing the previous fiscal year?s expenditures on behalf of a subrecipient. This written response will contain confirmation that the subrecipients have recorded the same expenditures in their accounting systems as OEM reported in the SEFA letter. Should there be any discrepancy between the information provided in the SEFA from OEM and the expenditures reported by the subrecipient, OEM will schedule a meeting to reconcile any differences and resolve discrepancies within 30 days of being notified of said discrepancies. The Director of Admin and Finance and the Assistant Deputy Chief of Administration will represent OEM in this meeting with the appropriate staff from the subrecipient reporting a discrepancy. Confirmation of resolution of any discrepancies will be documented in writing and attached to SEFA letters for record keeping purposes.

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 37561 2022-001
    Material Weakness
  • 37562 2022-002
    Significant Deficiency
  • 37563 2022-003
    Material Weakness Repeat
  • 37564 2022-004
    Material Weakness
  • 37565 2022-005
    Significant Deficiency
  • 37566 2022-006
    Significant Deficiency
  • 37567 2022-005
    Significant Deficiency
  • 37568 2022-006
    Significant Deficiency
  • 37569 2022-005
    Significant Deficiency
  • 37570 2022-006
    Significant Deficiency
  • 37571 2022-005
    Significant Deficiency
  • 37572 2022-006
    Significant Deficiency
  • 37573 2022-005
    Significant Deficiency
  • 37574 2022-006
    Significant Deficiency
  • 37575 2022-007
    Significant Deficiency
  • 614003 2022-001
    Material Weakness
  • 614004 2022-002
    Significant Deficiency
  • 614005 2022-003
    Material Weakness Repeat
  • 614006 2022-004
    Material Weakness
  • 614007 2022-005
    Significant Deficiency
  • 614008 2022-006
    Significant Deficiency
  • 614009 2022-005
    Significant Deficiency
  • 614010 2022-006
    Significant Deficiency
  • 614011 2022-005
    Significant Deficiency
  • 614012 2022-006
    Significant Deficiency
  • 614013 2022-005
    Significant Deficiency
  • 614014 2022-006
    Significant Deficiency
  • 614015 2022-005
    Significant Deficiency
  • 614016 2022-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $141.16M
21.027 Coronavirus State and Local Fiscal Recovery Funds $90.35M
84.425 Education Stabilization Fund $52.13M
21.019 Coronavirus Relief Fund $37.76M
84.010 Title I Grants to Local Educational Agencies $32.74M
10.555 National School Lunch Program $29.43M
14.267 Continuum of Care Program $29.00M
21.023 Emergency Rental Assistance Program $23.84M
84.027 Special Education_grants to States $19.37M
14.231 Emergency Solutions Grant Program $15.08M
97.067 Homeland Security Grant Program $10.22M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $4.43M
14.218 Community Development Block Grants/entitlement Grants $3.44M
84.367 Improving Teacher Quality State Grants $3.14M
14.889 Choice Neighborhoods Implementation Grants $2.50M
32.009 Emergency Connectivity Fund Program $2.42M
84.365 English Language Acquisition State Grants $2.15M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $2.14M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $1.91M
84.424 Student Support and Academic Enrichment Program $1.53M
93.053 Nutrition Services Incentive Program $1.46M
84.048 Career and Technical Education -- Basic Grants to States $1.29M
10.559 Summer Food Service Program for Children $1.15M
14.905 Lead Hazard Reduction Demonstration Grant Program $875,418
84.287 Twenty-First Century Community Learning Centers $798,800
84.173 Special Education_preschool Grants $705,763
10.582 Fresh Fruit and Vegetable Program $589,666
84.002 Adult Education - Basic Grants to States $493,394
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $461,145
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $434,221
16.034 Coronavirus Emergency Supplemental Funding Program $387,065
20.616 National Priority Safety Programs $330,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $327,657
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $327,115
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $230,558
16.741 Dna Backlog Reduction Program $228,189
14.241 Housing Opportunities for Persons with Aids $198,525
94.016 Senior Companion Program $180,387
14.401 Fair Housing Assistance Program_state and Local $179,360
47.076 Education and Human Resources $178,788
14.248 Community Development Block Grants_section 108 Loan Guarantees $151,694
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $139,975
97.042 Emergency Management Performance Grants $136,689
94.002 Retired and Senior Volunteer Program $134,065
84.196 Education for Homeless Children and Youth $133,025
93.052 National Family Caregiver Support, Title Iii, Part E $128,466
97.106 Securing the Cities Program $117,605
16.588 Violence Against Women Formula Grants $116,980
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $115,958
16.838 Comprehensive Opioid Abuse Site-Based Program $99,654
10.649 Pandemic Ebt Administrative Costs $82,855
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $77,511
97.047 Pre-Disaster Mitigation $75,000
45.149 Promotion of the Humanities_division of Preservation and Access $64,064
12.900 Language Grant Program $62,353
45.301 Museums for America $58,423
16.817 Byrne Criminal Justice Innovation Program $54,978
97.044 Assistance to Firefighters Grant $31,952
97.039 Hazard Mitigation Grant $29,550
14.261 Homeless Management Information Systems Technical Assistance $25,333
45.024 Promotion of the Arts_grants to Organizations and Individuals $22,500
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $22,337
10.331 Food Insecurity Nutrition Incentive Grants Program $18,005
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $17,540
16.015 Missing Alzheimer's Disease Patient Assistance Program $12,177
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $9,776
16.833 National Sexual Assault Kit Initiative $9,758
14.U00 Brownsfields Economic Development Initiative $7,379
20.600 State and Community Highway Safety $5,364
93.763 Alzheimer?s Disease Initiative: Specialized Supportive Services Project (adi-Sss) Thru Prevention and Public Health Funds (pphf) $2,777
84.411 Investing in Innovation (i3) Fund $1,836
20.205 Highway Planning and Construction $1,634
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $1,529