Finding Text
BCC 2022-05 [2021-003] ? REPORTING ? COMPLIANCE AND CONTROLS FEDERAL AGENCY: U.S. DEPARTMENT OF HOMELAND SECURITY, FEDERAL EMERGENCY MANAGEMENT AGENCY PASS-THROUGH ENTITY: FLORIDA EXECUTIVE OFFICE OF GOVERNOR, DIVISION OF EMERGENCY MANAGEMENT PROGRAM: DISASTER GRANTS-PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS), ALN 97.036 AWARD YEAR: DR 4177 ? 2014, DR 4399 - 2019 FINDING TYPE: MATERIAL WEAKNESS; MATERIAL NONCOMPLIANCE CRITERIA: 2 CFR 200.303(a) of the Uniform Guidance requires non-federal entities to establish and maintain effective internal control over Federal awards 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. Additionally, per the County?s grant agreements with Florida Division of Emergency Management (FDEM), quarterly reports are required to be submitted through FloridaPA.com that include project costs and expenditures for each large project. Amounts in the quarterly reports should reconcile to the County?s accounting records and represent actual expenditures. CONDITION: For fiscal year 2021, two large projects were tested for compliance with this requirement, including all quarterly reports submitted for these projects. This was not a statistically valid sample. For all quarterly reports tested, the reported expenditures per quarter were unable to be reconciled to actual expenditures in the quarter per the invoices and other supporting documentation in the County?s files. For fiscal year 2022, two large projects were tested for compliance with this requirement, including all quarterly reports submitted for these projects. The two projects make up the entire population of projects during fiscal year 2022. For all quarterly reports tested, the reported expenditures per quarter were unable to be reconciled to actual expenditures in the quarter per the invoices and other supporting documentation in the County?s files. CAUSE: This was believed to either be a timing difference between when expenditures were reported vs. when the activity actually occurred, and/or that the consulting staff preparing quarterly reports used estimated rather than actual expenditures in the quarterly reports. There was turnover in consulting staff handling the reports during fiscal year 2021 and staff may not have been properly trained. The issues continued in fiscal year 2022. EFFECT: The County is reporting incorrect project expenditures to FDEM in quarterly reports, which can affect project cost tracking. Under the terms of the grant agreements, submission of inaccurate or incomplete reports could result in FDEM ceasing disbursements to the County, termination of the agreements, or other remedies. Under Florida Statutes, FDEM is responsible for oversight of the operations of the federal award supported activities. Due to the County?s incorrect reporting, FDEM could be reporting incorrect expenditures to the federal agency. QUESTIONED COSTS: None. RECOMMENDATION: We recommend additional training for consulting staff handling quarterly reports to ensure the correct amounts are being included, and a specific review of quarterly report information by a higher level prior to submission to ensure accurate reporting of project costs. STATUS: The condition continues to exist. VIEWS OF RESPONSIBLE OFFICIALS: See Management?s Response and Corrective Action Plan beginning page 125.