Finding Text
United States Department of the Treasury Reference Number: 2022-008 Program: 21.023 COVID-19 Emergency Rental Assistance Federal Award Number: ERA-2101123208 & ERAE0280 Type of Finding: Noncompliance; Significant Deficiency in Internal Controls over Compliance Compliance Requirement: Reporting & Special Tests and Provisions Condition: The following conditions were found during audit testing of four monthly reports and one quarterly report for ERA 1 and ERA 2: DSHA internal procedures over the reporting did not require a secondary review prior to submission of the reports. 2. Supporting documentation was not retained for information reported on the reports selected for testing. We were unable to reconcile amounts reported on monthly and quarterly reports submitted to the U.S. Treasury to underlying records. Additionally, audit testing found the differences noted below between the reports submitted and records obtained during the audit: a. The ERA 1 report for the quarter ended June 30, 2022, reported program spending and obligations totaling $166,277,794. Actual ERA 1 expenditures through June 30, 2022, totaled approximately $93,350,000. Program obligations were not tracked or reported. b. We found the following differences in Federal Funding Accountability and Transparency Act reporting on the quarterly reports submitted to the U.S. Treasury: One subrecipient?s TIN number was appeared incorrectly in the subrecipients section of the quarterly report. ii. DSHA could not provide evidence that two program subrecipients were correctly included in the quarterly report. The following U.S. Treasury required reports were not submitted timely: Reports for the quarter ended September 30, 2021 were due on October 29, 2021 and were submitted on December 28, 2021. Reports for the quarter ended June 30, 2022, Were due to the U.S. Treasury on July 15, 2022 and were submitted on August 15, 2022. Criteria: United States Department of the Treasury ERA Program Reporting Guidance version 3.2 was issued March 29, 2022. The following sections of the Reporting guidance contain the key criteria: Pages 10 and 11 detail monthly and quarterly reporting deadlines for the entire period of performance. Page 38 includes the text of the Report Certification and Submission representation that includes the following: ?I certify that the information provided is accurate and complete after reasonable inquiry of people, systems, and other information available to the ERA Recipient. ??. CFR ? 200.303 - Internal controls requires the non-federal entity to 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. Questioned Costs: None. Context: . Monthly and Quarterly reports were required to be submitted for both ERA1 and ERA2. Effect: Reports required by the U.S. Treasury were not submitted timely and, accurately, and were not supported by contemporaneously prepared supporting documentation. Information necessary for the U.S. Treasury to calculate the required reallocations was not accurately reported on the quarterly reports submitted.