Finding 948512 (2023-005)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-03-04

AI Summary

  • Core Issue: The city submitted the same demolition costs for reimbursement from two different ARPA grants, leading to a duplication of $94,921.26.
  • Impacted Requirements: Costs must not be used for matching requirements of other federally-financed programs, as per 2 CFR Part 200.
  • Recommended Follow-Up: Contact grantor agencies to address questioned costs, file amended reports, and ensure staff training on cost standards.

Finding Text

INELIGIBLE COSTS / CRITERIA / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINSTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATES "EXCEPT WHERE OTHERWISE AUTHORIZED BY STATUTE, COSTS MUST MEET THE FOLLOWING CRITERIA IN ORDER TO BE ALLOWABLE UNDER FEDERAL AWARDS: (F) NOT BE INCLUDED AS A COST OR USED TO MEET COST SHARING OR MATCHING REQUIREMENTS OF ANY OTHER FEDERALLY-FINANCED PROGRAM IN EITHER THE CURRENT OR PRIOR PERIOD. / CONDITION / ON MAY 11, 2022 THE CITY WAS AWARDED AN ARPA GRANT THROUGH MISSISSIPPI COUNTY, MISSOURI FOR THE DEMOLITION OF A HAZARDOUS SCHOOL STRUCTURE IN ORDER TO FACILITATE THE CONSTRUCTION OF A PUBLIC HEALTH FACILITY. COSTS OF DEMOLITION WERE SUBMITTED AND REIMBURSED BY THE MISSISSIPPI COUNTY, MISSOURI ARPA GRANT IN AUGUST AND SEPTEMBER 2022. ON DECEMBER 12, 2022, THE CITY WAS AWARDED AN ARPA GRANT THROUGH THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION (DESE) FOR THE SAME PROJECT. THE GRANT REQUIRED A 50% MATCH. THE BUDGET SUBMITTED TO DESE INDICATED THAT THE GRANT FROM MISSISSIPPI COUNTY, MISSOURI WOULD BE USED AS A MATCH. ON DECEMBER 14, 2022, THE CITY SUBMITTED INVOICES TO DESE FOR REIMBURSEMENT IN THE AMOUNT OF $94,921.26. THE INVOICES SUBMITTED HAD PREVIOUSLY BEEN REIMBURSED BY THE MISSISSIPPI COUNTY ARPA GRANT. THUS, THE CLAIM FOR REIMBURSEMENT WAS DUPLICATED, AND THE CITY WAS REIMBURSED TWICE FOR THE SAME COSTS. / CAUSE / THE CITY RECEIVED A MISCOMMUNICATION REGARDING THE ELIGIBILITY OF COSTS. ALSO, THE CITY WAS NO FULLY AWARE OF THE COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. / EFFECT / THE CITY HAS DUPLICATED THE REQUEST FOR REIMBURSEMENT OF COSTS SUBMITTED TO THE DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND THE MISSISSIPPI COUNTY, MISSOURI IN THE AMOUNT OF $94,921.26. / QUESTIONED COSTS / THE AMOUNT OF $94,921.26 IS BEING QUESTIONED, SINCE THE COST HAS PREVIOUSLY BEEN REPORTED AS A COST OF ANOTHER PROGRAM. / PERSPECTIVE / THE FINDING IS AN ISOLATED INSTANCE, IN THAT THE QUESTIONED COSTS PERTAINED TO A SINGLE INVOICE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / I WOULD RECOMMEND CONTACTING THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND MISSISSIPPI COUNTY, MISSOURI, AND ADVISE THEM OF THE QUESTIONED COSTS. I WOULD RECOMMEND FILING AMENDED REPORTS AS NEEDED. ALSO, I WOULD RECOMMEND REQUESTING THAT OTHER ELIGIBLE COSTS BE SUBSTITUTED FOR THE REIMBURSEMENT. I WOULD ALSO RECOMMEND THAT THE CITY ADMINISTRATIVE STAFF FULLY REVIEW THE ADMINISTRATIVE AND COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. FURTHER, THE CITY SHOULD CONSULT WITH AN OUTSIDE PROFESSIONAL AS NEEDED. / MANAGEMENT RESPONSE / MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT WILL CONTACT THE GRANTOR AGENCIES TO RESOLVE THE MATTER AS QUICKLY AS POSSIBLE. FURTHER, THE ADMINISTRATIVE STAFF WILL RECEIVE TRAINING IN REGARDS TO THE ADMINISTRATIVE AND COST STANDARDS OF THE UNIFORM GUIDANCE. ALSO, OUTSIDE PROFESSIONALS WILL BE CONSULTED AS NEEDED.

Categories

Questioned Costs Eligibility Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Cash Management

Other Findings in this Audit

  • 372064 2023-004
    Significant Deficiency
  • 372065 2023-004
    Significant Deficiency
  • 372066 2023-005
    Significant Deficiency
  • 372067 2023-004
    Significant Deficiency
  • 372068 2023-004
    Significant Deficiency
  • 372069 2023-004
    Significant Deficiency
  • 372070 2023-005
    Significant Deficiency
  • 948506 2023-004
    Significant Deficiency
  • 948507 2023-004
    Significant Deficiency
  • 948508 2023-005
    Significant Deficiency
  • 948509 2023-004
    Significant Deficiency
  • 948510 2023-004
    Significant Deficiency
  • 948511 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $268,865
20.205 Highway Planning and Construction $228,527
10.766 Community Facilities Loans and Grants $127,780
21.027 Coronavirus State and Local Fiscal Recovery Funds $94,875