ASSOCIATION OF STATE FLOODPLAIN MANAGERS, INC.

Information on the Federal Program: U.S. Department of Homeland Security, CFDA #97.045, Cooperating Technical Partners, Year ended June 30, 2020. Criteria: The 2 U.S. Code of Federal Regulations (CFR) section 200.305(b)(3) of the Uniform Guidance requires that the costs from which reimbursement was requested were expended prior to the request for reimbursement. Condition: During the audit, the auditor became aware of expenses that were requested for reimbursement were prior to the expenses incurred. Cause: The billings were not reconciled to actual expenses recorded in the accounting system. Effect: Excess reimbursement amounts requested may be disallowed, and if any, in excess of $500 be returned to the federal agency. Indirect costs charged may be overstated. Repeat Finding: Yes. See prior year finding 2019-002. Auditor?s Recommendation: We recommend Association of State Floodplain Managers, Inc. review of billings and reconcile the billings to actual expenses recorded on the accounting system. Management Response: The Association of State Floodplain Managers (ASFPM) is dedicated to providing accurate billings to our funders. It has been ASFPM?s policy to true-up or reconcile our project billings with the accounting system upon completion of the project, however, we will follow our auditor?s recommendations to review and reconcile billings to the actual expenses recorded on the accounting system on at least an annual basis.

Information on the Federal Program: Department of Commerce, CFDA 11.473, Office for Coastal Management, Year ended June 30, 2019. Department of Commerce, CFDA 11.473, Office for Coastal Management, Passed through NACO Research Foundation, Grant No. NOA100-01, Year ended June 30, 2019. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Section 200.305(b)(3) indicates when the reimbursement method is used, costs for which reimbursement was requested was paid prior to the date of the reimbursement request. Condition: Testing of cash management disclosed a billing error made in the prior year requested costs not paid prior to the date of the reimbursement request and was not corrected when identified. Context and Questioned Costs: Two quarterly billings totaling $158,293 was selected for testing from a population of 8 quarterly billings totaling $376,662 for the federal program. The sample was not a statistically valid sample. The testing found both quarters actual expenses recorded in the accounting system to be less than billed. Annual billings were then compared to annual actual expenses recorded in the accounting system that noted total billings in excess of actual expenses of $1,102. Total award billings were then compared to total actual expenses which identified an error in the prior year that was not corrected. Total billings in excess of actual costs was $26,728. Effect: Excess reimbursement amounts requested may be disallowed and interest earned, if any, in excess of $500 be returned to the federal agency. Cause: A review and approval of billings that reconcile to actual expenses in the underlying accounting records was not performed. Costs applied to the matching requirement were included in the request for reimbursement. Repeat Finding: N/A Recommendation: We recommend a review of billings that reconcile to actual expenses in the underlying accounting records, excluding matching amounts. We also recommend any errors identified in billings should be corrected timely. Views of Responsible Officials and Planned Corrective Actions: Association of State Floodplain Managers, Inc. agrees with the finding and is implementing a review of billings to actual expenses with the December 31, 2019 quarterly billings.