Finding 966602 (2023-003)

Significant Deficiency
Requirement
C
Questioned Costs
$1
Year
2023
Accepted
2024-03-29
Audit: 301060
Organization: City of Daly City (CA)

AI Summary

  • Core Issue: The City improperly drew down $17,301 in Community Development Block Grant funds before actual cash expenditures, violating cash management rules.
  • Impacted Requirements: This practice does not comply with 2 CFR 200.305, which mandates minimizing the time between fund receipt and expenditure.
  • Recommended Follow-Up: The City should only draw down funds after cash payments are made and assess if any interest earned on advanced funds needs to be returned.

Finding Text

Finding Reference Number: SA2023-003 Cash Management - Draw Down of Community Development Block Grant Funds in Advance of Disbursement Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-22-MC-06-0010 COVID-19 - B-20-MW-06-0010 Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash need, and must minimize the time elapsing between the transfer of funds from its line of credit, and the disbursement of the funds. Advance payment must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the grantee or subrecipient carrying out an eligible activity. Condition: We selected eight non-payroll disbursements related to projects and subgrants for testing and noted two disbursement in April 2023 and June 2023 totaling $268,439 had been charged to the CDBG program in the amount of $282.567. The difference of $14,128 was the retention payable to the vendor, which was not paid in cash until after June 30, 2023. However, the City included the retentions payable in the grant drawdowns filed and received in May 2023 and September 2023. We also noted that total retentions payable charged to the CDBG program for the project were $17,301 as of June 30, 2023. Cause: We understand that the retentions were included in the grant drawdowns due to staff oversight. Questioned Costs: We question costs in the amount of $17,301. Effect: Drawing down funds in advance does not minimize the time elapsing between receipt of funds and expenditures and is not in compliance with the cash management provisions of 2 CFR 200.305 and the CDBG program. Recommendation: The City should not draw down funds until expenditures have been paid in cash and in the event, drawdowns occur prior to disbursement, ensure that the time elapsing between the draw down and the expenditure is minimized. In addition, the City should determine whether the interest earned on the grant funds advanced need to be returned to the grantor. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Categories

Questioned Costs Cash Management

Other Findings in this Audit

  • 390155 2023-001
    Significant Deficiency Repeat
  • 390156 2023-001
    Significant Deficiency Repeat
  • 390157 2023-002
    Significant Deficiency
  • 390158 2023-002
    Significant Deficiency
  • 390159 2023-003
    Significant Deficiency
  • 390160 2023-003
    Significant Deficiency
  • 966597 2023-001
    Significant Deficiency Repeat
  • 966598 2023-001
    Significant Deficiency Repeat
  • 966599 2023-002
    Significant Deficiency
  • 966600 2023-002
    Significant Deficiency
  • 966601 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.218 Community Development Block Grants/entitlement Grants $706,471
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $313,948
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $182,120
14.239 Home Investment Partnerships Program $126,888
20.205 Highway Planning and Construction $102,586
21.027 Coronavirus State and Local Fiscal Recovery Funds $96,575
16.922 Equitable Sharing Program $74,282
93.053 Nutrition Services Incentive Program $51,698
16.738 Edward Byrne Memorial Justice Assistance Grant Program $37,722
10.576 Senior Farmers Market Nutrition Program $6,500