Lakefront Management AuthorityLocal Government

Criteria: According to 2 CFR 200.502, the determination of when a federal award is expended must be based on when the activity related to the federal award occurs. Generally, the activity related to the federal award pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grants. For FEMA grants, non-federal entities must record expenditures on the SEFA when (1) FEMA has approved the nonfederal entity’s project, and (2) the non-federal entity has incurred the eligible expenditures. FEMA’s approval of a subaward is indicated when FEMA obligates the federal share of the eligible project cost to the recipient Federal awards expended in years subsequent to the fiscal year in which the project is approved are to be recorded on the non-federal entity’s SEFA in those subsequent years. Condition: The Authority's expenditures relating to FEMA awards obligated during the current fiscal year did not include expenditures incurred during previous fiscal years. Effect: The Authority's expenditures were understated which could have impaired proper major program determination for testing and caused a misstatement of the SEFA. Cause: The Authority experienced turnover in its grants administrator position, which led to a loss of institutional knowledge and reduced continuity in its grant management processes. As a result, the Authority faced increased difficulty complying with the unique reporting requirements applicable to FEMA awards. Recommendation: We recommend that the Authority enhance its grants administration processes by establishing formal, written procedures that address the unique reporting requirements of FEMA awards. The Authority should ensure that staff responsible for grant management receive sufficient training and that cross-training is in place to mitigate the effects of future turnover. These steps will help preserve institutional knowledge, promote consistent application of required procedures, and improve compliance with FEMA reporting standards. Views of Responsible Officials: Management agrees with the finding and will implement controls to ensure all awards are included, as well as correct going forward. See Management’s Corrective Action Plan for further details.