Finding Text
2023 – 007 Reporting
Federal Agency: Department of the Treasury
Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds (ARPA)
ALN: 21.027
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Number and Period: 1505-0271
3/3/2021 – 12/31/2024
Statistically Valid Sample: No, and not intended to be a statistically valid sample
Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance
Criteria or specific requirement: Per the Compliance and Reporting Guidance : State and Local
Fiscal Recovery Funds (SLFRF) Version 5.2, 2. Annual Reporting: The following recipients are required
to submit annual Project and Expenditure Reports:
• Tribal governments that are allocated less than $30 million in SLFRF funding
• Metropolitan cities and counties with a population below 250,000 residents that are allocated
less than $10 million in SLFRF funding and NEUs that are allocated less than $10 million in
SLFRF funding
For these recipients, the initial Project and Expenditure Report covered from March 3, 2021 to
March 31, 2022 and was required to be submitted to Treasury by April 30, 2022. The subsequent
annual reports will cover one calendar year and must be submitted to Treasury by April 30.
3. Required Information: The following information is required in Project and Expenditure Reports for
both quarterly and annual reporting:
Projects: Provide information on all SLFRF funded projects. Projects are defined as a grouping of
closely related activities that together are intended to achieve a specific goal or are directed toward a
common purpose. These activities can include new or existing eligible government services or
investments funded in whole or in part by SLFRF funding. For each project, the recipient is required to
enter the project name, identification number (created by the recipient), project expenditure category
(see Appendix 1), description, and status of completion. Project descriptions must describe the project
in sufficient detail to provide an understanding of the major activities that will occur, and must be
between 50 and 250 words.
Project descriptions for the emergency relief from natural disasters eligible use category must describe
the natural disaster the recipient is responding to, including the type of event, and how the emergency
relief is related to and reasonably proportional to the natural disaster. a. Projects should be defined to include only closely related activities directed toward a common
purpose. Recipients should review the Required Programmatic Data described in 3.g. below and define
their projects at a sufficient level of granularity.
Note: For each project, the recipient is asked to select the appropriate Expenditure Category based on
the scope of the project (see Appendix 1). Projects should be scoped to align to a single Expenditure
Category. For select Expenditure Categories, the recipient also is asked to provide additional
programmatic data.
Condition: Audit procedures included testing the Annual SLFRF Compliance Report. During the testing
of the Compliance report, it was noted that the report’s Project Description and explanation of how the
revenue replacement funds were allocated to government services did not agree with the provided
expenditure support for the current fiscal year.
Reported Project Description: The City of Nogales used the money for ongoing Public Safety
expenditures. Provided expenditures support contained Covid-19 emergency response
purchases, public health purchases and water and sewer infrastructure cost.
Reported explanation of how revenue replacement funds were allocated to government
services: Paid the PSPRS current employer portion for fire and police for FY23. Provided
expenditure support did not contain PSPRS expenditures.
Questioned costs: Unknown
Context: See “Condition.”
Cause: Current controls are not at the correct precision level to detect errors in the
answers/explanations reported prior to submission.
Effect: The City is not in compliance with Compliance and Reporting Guidance: State and Local Fiscal
Recovery Funds Version 5.2, 2.grant guidance requirements related to reporting.
Repeat Finding: No
Recommendation: The City of Nogales should enhance and/or modify existing controls over reporting
to in order to prevent reporting noncompliance and ensure adherence to all grant guidance
requirements.
Views of responsible officials: See corrective action plan.
Corrective action plan: See corrective action plan.