Finding 978900 (2023-006)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-06-26
Audit: 309973
Organization: City of Cambridge Massachusetts (MA)
Auditor: Kpmg

AI Summary

  • Core Issue: The City failed to report subawards over $30,000 to subrecipients on time, violating FFATA requirements.
  • Impacted Requirements: Reporting obligations under the Federal Funding Accountability and Transparency Act (FFATA) and internal control standards as outlined in 2 CFR Part 200.
  • Recommended Follow-Up: Enhance policies and procedures to ensure timely FFATA reporting, using the contract start date as the obligation date for future submissions.

Finding Text

Program: Housing Opportunities for Persons with AIDS (HOPWA) ALN #: 14.241 Federal Agency: Housing and Urban Development Federal Award Numbers: MAH22-F005, MAH20-F005, and MAH21-F005 Award Year: July 1, 2022–June 30, 2023 Reporting Type of finding: Material weakness and noncompliance Prior-year finding: No Statistically valid sample: No Criteria Special Reporting for Federal Funding Accountability and Transparency Act Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, herein referred to as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., 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). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Title 2 US Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 200.1 defines subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 2 CFR 200.1 defines subrecipient as a nonfederal entity that receives a subaward from a passthrough entity to carry out part of a federal program but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Lastly, 2 CFR 200.303(a) states, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 be in compliance 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 City’s Community Development Department did not report awards granted to subrecipients for the HOPWA program by the end of the month following the month in which the City awarded the subrecipient award that is greater than or equal to $30,000 as required by FFATA. FFATA requires the City to report certain identifying information related to awards made to subrecipients in amounts greater than or equal to $30,000. Of the information to be reported, the following key data elements are required to be audited: 1. Subawardee name 2. Subawardee DUNS/UEI number 3. Amount of subaward 4. Subaward obligation/action date 5. Date of report submission 6. Subaward number 7. Subaward project description 8. Subawardee names and compensation of highly compensated officers During our testing, we noted that the City did not establish control procedures to submit FFATA reports for all subawards as required by federal regulations. During our testwork of four subawards, we also noted reporting exceptions as subawards were not reported in the required time. Cause The condition found was due to the City not reporting any amounts passed through to subrecipients for the period from July 2022 to June 2023, as the responsible officials were not aware of the reporting timeline requirements. As a result, all subawards were reported on a one-year lag. Effect Failure to submit all subaward amounts passed through to subrecipients and subcontractors under subawards as defined by 2 CFR 200.1 in the City’s FFATA reporting could result in the City reporting inaccurate and incomplete amounts to the federal government Questioned Costs None Recommendation We recommend that the City review and enhance its policies, procedures, and internal controls to ensure that all amounts passed through to subrecipients under subawards as defined in 2 CFR 200.1 are reported in accordance with the FFATA federal regulations. In addition, we recommend that the City use obligation date for FFATA reporting. Views of Responsible Officials and Corrective Actions HOPWA contracts have typically been obligated over the course of several or more months, as some subrecipients operate in different ways. Going forward, the City will use the contract start date (7/1) as the Obligation date, and will submit the FFATA report accordingly. Implementation Date 8/31/2024 (representing the end of the month following the obligation of funds). Responsible Officials Robert Keller, Project Planner, Cambridge Community Development Department, and Judith Tumusiime, Federal Grants Manager, Cambridge Community Development Department

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness Period of Performance Reporting

Other Findings in this Audit

  • 402448 2023-001
    Significant Deficiency Repeat
  • 402449 2023-001
    Significant Deficiency Repeat
  • 402450 2023-002
    Material Weakness Repeat
  • 402451 2023-002
    Material Weakness Repeat
  • 402452 2023-003
    Material Weakness Repeat
  • 402453 2023-003
    Material Weakness Repeat
  • 402454 2023-004
    -
  • 402455 2023-005
    Material Weakness
  • 402456 2023-005
    Material Weakness
  • 402457 2023-006
    Material Weakness
  • 402458 2023-006
    Material Weakness
  • 402459 2023-007
    Material Weakness
  • 402460 2023-007
    Material Weakness
  • 402461 2023-008
    Material Weakness
  • 402462 2023-008
    Material Weakness
  • 402463 2023-009
    Material Weakness
  • 402464 2023-009
    Material Weakness
  • 402465 2023-010
    Material Weakness
  • 402466 2023-010
    Material Weakness
  • 402467 2023-011
    Material Weakness
  • 402468 2023-011
    Material Weakness
  • 978890 2023-001
    Significant Deficiency Repeat
  • 978891 2023-001
    Significant Deficiency Repeat
  • 978892 2023-002
    Material Weakness Repeat
  • 978893 2023-002
    Material Weakness Repeat
  • 978894 2023-003
    Material Weakness Repeat
  • 978895 2023-003
    Material Weakness Repeat
  • 978896 2023-004
    -
  • 978897 2023-005
    Material Weakness
  • 978898 2023-005
    Material Weakness
  • 978899 2023-006
    Material Weakness
  • 978901 2023-007
    Material Weakness
  • 978902 2023-007
    Material Weakness
  • 978903 2023-008
    Material Weakness
  • 978904 2023-008
    Material Weakness
  • 978905 2023-009
    Material Weakness
  • 978906 2023-009
    Material Weakness
  • 978907 2023-010
    Material Weakness
  • 978908 2023-010
    Material Weakness
  • 978909 2023-011
    Material Weakness
  • 978910 2023-011
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $11.36M
14.267 Continuum of Care Program $4.82M
84.425U American Rescue Plan Elementary and Secondary School Emergency Relief $2.88M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $2.59M
14.218 Community Development Block Grants/entitlement Grants $2.26M
84.425D Elementary and Secondary School Emergency Relief Fund (esser) $1.83M
10.555 National School Lunch Program $1.78M
93.568 Low-Income Home Energy Assistance $1.36M
84.010 Title I Grants to Local Educational Agencies $1.33M
21.027 Coronavirus State and Local Fiscal Recovery Funds $631,858
14.231 Emergency Solutions Grant Program $447,934
97.067 Homeland Security Grant Program $395,216
10.553 School Breakfast Program $350,371
84.027 Special Education_grants to States $342,165
32.004 Universal Service Fund - Schools and Libraries $238,716
10.559 Summer Food Service Program for Children $235,325
84.367 Improving Teacher Quality State Grants $178,360
84.002 Adult Education - Basic Grants to States $165,716
32.009 Emergency Connectivity Fund Program $158,827
93.590 Community-Based Child Abuse Prevention Grants $150,159
84.048 Career and Technical Education -- Basic Grants to States $99,323
84.365 English Language Acquisition State Grants $85,904
14.881 Moving to Work Demonstration Program $84,885
84.424 Student Support and Academic Enrichment Program $82,790
84.173 Special Education_preschool Grants $45,562
14.241 Housing Opportunities for Persons with Aids $45,047
97.042 Emergency Management Performance Grants $39,600
84.425 Education Stabilization Fund $30,287
84.196 Education for Homeless Children and Youth $15,549
14.401 Fair Housing Assistance Program_state and Local $12,746
20.616 National Priority Safety Programs $12,189
97.024 Emergency Food and Shelter National Board Program $11,885
20.600 State and Community Highway Safety $11,337
16.738 Edward Byrne Memorial Justice Assistance Grant Program $10,008
93.499 Low Income Household Water Assistance Program $9,554
93.788 Opioid Str $5,889
84.287 Twenty-First Century Community Learning Centers $363