Finding 83097 (2022-001)

Howard County respectively submits the following corrective action plan for the year ended June 30, 2022. 2022-001 Federal Agency: Department of Housing and Urban Development Federal Program Name: CDBG Entitlement Grant Cluster ALN: 14.218 Award Number: B-18-UC-24-0012, B-19-UC-24-0012, B20-UW-24-0012, B20-UC-24-0012, B- 21-UC- 24-0012 Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Prior Year Finding: No Criteria: Compliance: Per the Federal Funding Accountability Transparency Act (FFATA), prime(direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Sub awardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 2 Howard County Government, Calvin Ball County Executive www.howardcountymd.gov 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity 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. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County did not accurately report required subaward information to FSRS for firsttier subawards of $30,000 or more. Questioned Costs: None Cause: The County?s policies and procedures were not sufficient to ensure that the required subaward information was reported to FSRS. Internal controls did not prevent or detect the errors. Effect: Subawards were not reported in FSRS in accordance with FFATA requirements. Recommendation: We further recommend the County to develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS. Views of Responsible Officials: The County agrees with the finding and recommendation. The staff of the Howard County Department of Housing & Community Development (DHCD) will implement a process to ensure that FSRS reporting is completed no later than the end of the month following the month a sub award agreement has been executed. Action taken in response to the finding: DHCD obligates subawards on the date a grant agreement has been fully executed with a subrecipient. To ensure that the required subaward information is reported to FSRS accurately and in a timely manner, an internal process has been established where the FSRS reporting will be completed on or about the same time as the fully executed grant agreement is received. The DHCD Home Program Specialist will be responsible for submitting the FFATA report in FSRS. Name of contact person (s) responsible for the corrective action plan: Maggie Carnegie/ Elizabeth Meadows ? Howard County Department of Housing & Community Development Planned completion date for the corrective action plan: June 30, 2023