City of Council Bluffs, Iowa

Assistance Listing Number 14.218 – CDBG Entitlement/Special Purpose Grants Cluster Department of Housing and Urban Development, Award Number B-24-MC-19-005 Award Period – January 1, 2024 – September 1, 2031 Criteria or specific requirement – Subaward agreements, amendments, and modifications that are at or above the subaward reporting requirement under Title 2 of the Code of Federal Regulations must be reported in the Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward or subaward amendment obligation was made. Condition – Subaward information was not reported in FSRS within the required time frame. Cause – Federal awards are awarded by the federal agency late in the calendar year with effective dates of January 1 of the same year. This results in subawards being obligated late in the calendar year after the grant has been awarded to the City. The City reported subaward information in FSRS before the calendar year ended. Effect - Reporting provides information to the public to hold the government accountable for each spending decision and assist with reducing wasteful spending. Untimely reporting does not provide an accurate detail of government spending. Questioned costs - None. Context – Subaward agreements and modifications were obligated during fiscal year 2025 to which the FFATA requirements applied. We selected a sample of one subaward out of a population of three. The one subaward tested was not submitted in a timely manner. The sample was not, and was not intended to be, a stastically valid sample. Identification as a repeat finding, if applicable – See 2024-001. Recommendation – We recommend that procedures related to reporting of subaward information in FSRS be improved to provide timely reporting. Views of responsible officials and planned corrective actions – Housing and Economic Development Staff will update its internal policy to submit FFATA within 30 days of the final execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these listed agreements. The original agreements typically happen in October and will be completed by November to meet the standard of submission within 30 days of allocation. We will also review amendments to ensure they are also filed within 30 days of execution.

We have reviewed procedures and plan to make the necessary changes to improve reporting timeliness. Staff will update its internal policy to submit the FFATA within 30 days of execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these agreements. Contact Person, Title, Phone Number Christopher Gibbons, Interim Director of Community Development, (712) 890-5358 Anticipated Date of Completion January 30, 2026

2024-001

Assistance Listing Number 14.218 CDBG Entitlement/Special Purpose Grants Cluster Department of Housing and Urban Development, Award Number B-22-MC-19-0005 Department of Housing and Urban Development, Award Number B-23-MC-19-0005 Criteria or specific requirement – Subaward agreements, amendments, and modifications that are at or above the subaward reporting requirement under Title 2 of the Code of Federal Regulations must be reported in in the Subaward Reporting System (FSRS) no later than the last day of the month following the month is which the subaward or subaward amendment obligation was made. Condition – Subaward information was not reported in FSRS within the required time frame. Questioned costs – None. Context – Subaward agreements and modifications were obligated during fiscal year 2024 to which the FFATA requirements applied. Of the one subaward and modification tested, none were submitted in a timely manner. Sampling was not a statistically valid sample. Effect – Reporting provides information to the public to hold the government accountable for each spending decision and assist with reducing wasteful spending. Untimely reporting does not provide an accurate detail of government spending. Cause – Federal awards are awarded by the federal agency late in the calendar year with effective dates of January 1 of the same year. This results in subawards being obligated late in the calendar year after the grant has been awarded to the City. The City reported subaward information in FSRS before the calendar year ended. Recommendation – We recommend that procedures related to the reporting of subaward information in FSRS be improved to provide timely reporting. View of responsible officials – Housing and Economic Development Staff will update its internal policy to submit FFATA with 30 days of the final execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these listed agreements. The original agreements typically happen in October and will be completed by November to meet the standard of submitting within 30 days of allocation. We will also review amendments to ensure they are also filed within 30 days of execution.

We have reviewed procedures and plan to make the necessary changes to improve reporting timeliness. Staff will update its internal policy to submit the FFATA with 30 days of execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these agreements.