Finding 8353 (2022-002)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-01-12
Audit: 11164
Organization: Van Wert County (OH)

AI Summary

  • Core Issue: The County reimbursed payroll expenses totaling $993,575 for periods before March 3, 2021, using federal funds, which violates the established period of performance.
  • Impacted Requirements: Expenditures must only cover costs incurred between March 3, 2021, and December 31, 2024, with all obligations liquidated by December 31, 2026.
  • Recommended Follow-Up: The County should implement procedures to ensure only eligible expenditures are charged to federal awards and establish a tracking system for federal expenditures to maintain compliance.

Finding Text

2 CFR § 1000 gives regulatory effect to the Department of the Treasury for 2 CFR Part 200. 2 CFR § 200.1 states, in part, that the term “Period of performance” means the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Identification of the period of performance in the Federal award per § 200.211(b)(5) does not commit the awarding agency to fund the award beyond the currently approved budget period. 2 CFR § 200.211(b)(5) states, in part, that the Federal awarding agency must include the following general Federal award information in each Federal award the Period of Performance Start and End Date. The period of performance for the award under the Coronavirus State and Local Fiscal Recovery begins on the date the awards are issued (i.e., the date funds are disbursed to recipients) and ends on December 31, 2026. Recipients may only use funds to cover costs incurred after March 3, 2021, and ending on December 31, 2024. Recipients must liquidate all obligations incurred by December 31, 2024, under the award no later than December 31, 2026, which is the end of the period of performance. 2021 Treasury SLFRF Compliance Supplement Addendum 1, 21.027; 2022 OMB Compliance Supplement, Part 4, 21.027. The County reimbursed payroll for all of fiscal year 2021 General Fund gross wages, using Coronavirus State and Local Fiscal Recovery funds, which included pay dates prior to March 3, 2021. The total gross wages reimbursed prior to March 3, 2021, was $993,575. Expenditures paid from federal funds outside the period of performance could result in federal questioned costs and follow-up action taken by the grantor agency, which may result in loss of future federal funding. The County should establish and implement procedures to verify that only expenditures incurred during the period of performance are charged to federal awards. Noncompliance with grant requirements could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit. County management should review all grant award documents in order to execute policies and procedures which help ensure compliance with grant requirements, including Schedule reporting requirements. The County should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the County is in compliance with grant requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.

Corrective Action Plan

The Corrective action plan will be to follow the period of performance going forward in order to not have this reoccur again in the future. The County management will review all grant documents to make sure they are in Compliance with the requirements. Van Wert County adopted the Standard Allowance for revenue loss up to $10 million for the ARPA funds. Lost revenue dates will be reviewed in the future to ensure supporting documents are also in Compliance with the grant requirements.

Categories

Period of Performance Reporting

Other Findings in this Audit

  • 584795 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $5.06M
93.558 Temporary Assistance for Needy Families $871,216
93.563 Child Support Enforcement $490,237
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $485,263
93.778 Medical Assistance Program $322,123
93.667 Social Services Block Grant $307,691
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $197,329
14.228 Target of Opportunity Program $169,440
14.239 Home Investment Partnerships Program $133,133
93.658 Foster Care_title IV-E $124,823
93.659 Adoption Assistance $55,143
17.258 Wia Adult Program $47,333
97.042 Emergency Management Performance Grants $40,930
93.645 Stephanie Tubbs Jones Child Welfare Services Program $34,285
17.278 Wia Dislocated Worker Formula Grants $33,074
17.259 Wia Youth Activities $17,362
17.225 Unemployment Insurance $14,048
93.575 Child Care and Development Block Grant $13,176
93.556 Promoting Safe and Stable Families $11,196
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $10,543
20.600 State and Community Highway Safety $8,375
90.404 2018 Hava Election Security Grants $8,001
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $7,160
97.039 Hazard Mitigation Grant $4,329
10.555 National School Lunch Program $3,426
10.553 School Breakfast Program $2,075
17.277 Workforce Investment Act (wia) National Emergency Grants $980
93.747 Elder Abuse Prevention Interventions Program $160