SMART GROWTH AMERICANon-Profit

Federal Program Information: U.S. Environmental Protection Agency: Environmental Policy and Innovation Grants, CFDA #66.611 Criteria or Specific Requirement: 2 CFR Part 215.21(b)(3) states that recipients? financial management systems shall provide for, ?Effective control over and accountability for all funds, property and other assets.? Good internal controls dictate that the personnel expenditures review process should be completed in order to ensure that the expenditures are allowed and in the proper period; documentation should be retained as evidence that the expenditures review process was completed. Condition and Context: For five of 40 personnel expenditures tested during our testing over internal controls, evidence of time incurred, and evidence of review and approval of the sampled employee?s time charged to the project was not maintained. The time charged to the project was based on a project manager's request to charge a portion of the employee?s time to the grant, as the employee had spent time on the project at various points in time but no cost had yet been charged to the grant for the time. The budget for the project does show time should be allocated for the employee?s position, evidencing that the employee was approved to work on the project. The total cost of the employee's salary charged to the projects in 2019 was $10,437. Fringe and indirect costs attributable to that amount were $2,115 and $4,792, respectively, for a total impact of $17,344. Questioned Costs: None. Effect: Without adequate evidence of time incurred and evidence of review and approval of the expenditures, the possibility exists that SGA could have incorrectly charged the programs. Cause: SGA did not maintain any evidence of their review and approval of the employee?s time charged to the federal major program during 2019; therefore, SGA does not have evidence of review and approval of the expenditures in 2019. Recommendation: SGA should ensure that appropriate reviews and documentation of such are performed by trained staff to verify the accuracy of the costs being charged to each program. Views of Responsible Officials and Planned Corrective Actions: SGA?s time-keeping system and controls are highly effective in preventing erroneous or incorrect charging of time to projects funded with federal awards during the regular course of business. Thus, the corrective action is tailored to address the issue of re-coding time after a timecard has been submitted, approved, and posted. Each of these actions reinforces existing SGA procedures. Planned Corrective Actions: 1. Provide annual training to project managers of projects funded through federal awards and to employees assigned to work on them regarding the requirement to complete and accurately document time charged to federal awards; 2. Decline requests to recode time to federal awards unless the project manager and/or the employee in question can provide documentation that supports the assertion that the specific hours in question were spent working on that project. Documentation may include the employee?s calendar but should also include some other form of back-up such as contemporaneous meeting notes, agendas, or emails and other work products that provide direct evidence of the employee?s effort. 3. Maintain all documentation and a record of the decision to approve the recoding with the payroll records for the affected time period(s).

Federal Program Information: U.S. Environmental Protection Agency: Environmental Policy and Innovation Grants, CFDA #66.611 Criteria or Specific Requirement: 2 CFR Part 180.300 states, ?When you enter into a covered transaction with another entity/person at the next lower tier, you must verify that the entity/person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM exclusions; or (b) Collecting a certification from that entity/person; or (c) Adding a clause or condition to the covered transaction with that entity/person.? Condition and Context: For two of two vendors tested, neither had a clause in their contracts stating they were not suspended or debarred. SGA asserts that the Director of Finance and Administration or the project manager verifies that potential vendors are not suspended or debarred via search of the SAM.gov website, but evidence of such verification is not maintained. We verified that the vendors were not suspended or debarred via search of the SAM.gov website. Questioned Costs: None. Effect: The vendors of SGA could potentially be suspended or debarred, causing SGA to be noncompliant with suspension and debarment requirements. Cause: SGA did not have adequate internal controls in place to ensure providers of goods or services are neither suspended nor debarred by a Federal agency. Recommendation: We recommend SGA establish procedures to ensure entities/persons with whom they intend to do business are not suspended or debarred. SGA should retain documentation of all verifications to support their review process. Views of Responsible Officials and Planned Corrective Actions: SGA will 1. Obtain certifications regarding eligibility for federal award funding from all current vendors on federally funded projects; 2. For future awards and contracts, review and document Suspension and Debarment status of all entities/persons considered as sub-contractors or sub-recipients of federal award funds before entering into agreements with them; 3. Incorporate standard language regarding the requirement to maintain eligibility for federal awards into all future agreements and contracts. Planning Implementation Date of Corrective Action: March 2020 Person Responsible for Corrective Action: Director of Finance and Administration

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION