EIN: 466000380
UEI: KN7AL7HF44B3
Audited by: KETEL THORSTENSON, LLP
Cognizant agency: 21 [Department of the Treasury]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 26, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 26, 2026 (164 days ago).
What is a management decision? →Finding No. 2024-003: Suspension and Debarment Requirement Federal Program Affected: Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027 Compliance Requirement: Procurement, Suspension, and Debarment Questioned Costs: None Condition and Cause: The City did not adhere to their written policies regarding suspension and debarment. Criteria and Effect: Before entering into a contract using federal funding, the City must determine the vendor is not suspended or debarred. A lack of proper identification of federal grant compliance requirements could result in improper use of grant revenue and improper reporting on the schedule of expenditures of federal awards. Recommendation: The City should verify vendors are not suspended or debarred prior to entering a contract using federal funding. Repeat Finding from Prior Year: No. Response/Corrective Action Plan: The City agrees with the above finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding No. 2024-003: Suspension and Debarment Requirement Federal Program Affected: Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027 Compliance Requirement: Procurement, Suspension, and Debarment Questioned Costs: None Condition and Cause: The City did not adhere to their written policies regarding suspension and debarment. Criteria and Effect: Before entering into a contract using federal funding, the City must determine the vendor is not suspended or debarred. A lack of proper identification of federal grant compliance requirements could result in improper use of grant revenue and improper reporting on the schedule of expenditures of federal awards. Recommendation: The City should verify vendors are not suspended or debarred prior to entering a contract using federal funding. Repeat Finding from Prior Year: No. Response/Corrective Action Plan: The City agrees with the above finding. See Corrective Action Plan.
2024-003 FINDING: Suspension and Debarment Requirement Responsible Officials: Daniel Ainslie, Finance Director, Joel Landeen, City Attorney Corrective Action Plan: The Finance office will collaborate with the Attorney’s office to ensure that all request for proposals/bids and contract agreements contain language confirming that bidder/awardee has not been suspended or debarred. The bid opening process will include steps to verify that the required documentation is included in bid packages. Anticipated Completion Date: December 31, 2025
Finding No. 2024-004: Period of Performance Federal Program Affected: Federal Transit – ALN 20.526 & ALN 20.526 Compliance Requirement: Period of Performance Questioned Costs: $168,976 Known Questioned Costs Condition and Cause: The City did not have a control process in place to verify and have written approval for federal funding reimbursement requests submitted outside of the grant award period of performance. Criteria and Effect: The City’s internal control structure failed to obtain written approval for grant extensions on reimbursement requests submitted for expenditures outside of individual grant award period of performance. The City did not track pre-award costs to ensure proper cutoff of grant expenditures. The lack of controls resulted in noncompliance with program requirements and questioned costs to the program. All questioned costs related to period of performance was identified during testing. Recommendation: The City should obtain written approval or grant award extensions before incurring expenditures and submitting for reimbursement from the federal program outside of the grant award period of performance. Repeat Finding from Prior Year: No Response/Corrective Action Plan: The City agrees with the above finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding No. 2024-004: Period of Performance Federal Program Affected: Federal Transit – ALN 20.526 & ALN 20.526 Compliance Requirement: Period of Performance Questioned Costs: $168,976 Known Questioned Costs Condition and Cause: The City did not have a control process in place to verify and have written approval for federal funding reimbursement requests submitted outside of the grant award period of performance. Criteria and Effect: The City’s internal control structure failed to obtain written approval for grant extensions on reimbursement requests submitted for expenditures outside of individual grant award period of performance. The City did not track pre-award costs to ensure proper cutoff of grant expenditures. The lack of controls resulted in noncompliance with program requirements and questioned costs to the program. All questioned costs related to period of performance was identified during testing. Recommendation: The City should obtain written approval or grant award extensions before incurring expenditures and submitting for reimbursement from the federal program outside of the grant award period of performance. Repeat Finding from Prior Year: No Response/Corrective Action Plan: The City agrees with the above finding. See Corrective Action Plan.
2024-004 FINDING: Period of Performance Responsible Officials: Daniel Ainslie, Finance Director, Jamie Toennies, Grants Division Manager Corrective Action Plan: Written communication will be sent to department directors and staff involved in grant administration addressing the compliance requirements associated with Period of Performance. This communication will specifically state that no federal funds will be spent outside of this time period without written approval by grantor and/or approved budget modification. In addition, the City’s Uniform Grant Guidance Polices/Procedures will be updated to include a section on Period of Performance compliance requirements. Anticipated Completion Date: December 31, 2025
FAC accepted this audit on September 25, 2024 — management decision was due March 25, 2025.
FAC accepted this audit on September 25, 2023 — management decision was due March 25, 2024.
Finding No. 2022-004: Tracking Federal Grant Funding Federal Program Affected: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) ? AL# 21.027 Compliance Requirement: Reporting Questioned Costs: None Condition and Cause: The City does not have a proper review process for the CSLFRF program expenditures allocated between the various grant agreements. In addition, reimbursement requests are not completed timely. Criteria and Effect: A lack of proper controls over federal expenditures could result in charging expenditures to multiple federal awards or ?double-dipping? of CSLFRF grant monies and improper reporting on the schedule of expenditures of federal awards. Timely reimbursement requests reduce the cash flow burden on the City. Recommendation: The City should implement a process for reviewing expenditure allocations between separate CSLFRF grants and submit reimbursement requests as soon as administratively feasible. Repeat Finding from Prior Year: N/A Response/Corrective Action Plan: The City agrees with the above finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding No. 2022-004: Tracking Federal Grant Funding Federal Program Affected: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) ? AL# 21.027 Compliance Requirement: Reporting Questioned Costs: None Condition and Cause: The City does not have a proper review process for the CSLFRF program expenditures allocated between the various grant agreements. In addition, reimbursement requests are not completed timely. Criteria and Effect: A lack of proper controls over federal expenditures could result in charging expenditures to multiple federal awards or ?double-dipping? of CSLFRF grant monies and improper reporting on the schedule of expenditures of federal awards. Timely reimbursement requests reduce the cash flow burden on the City. Recommendation: The City should implement a process for reviewing expenditure allocations between separate CSLFRF grants and submit reimbursement requests as soon as administratively feasible. Repeat Finding from Prior Year: N/A Response/Corrective Action Plan: The City agrees with the above finding. See Corrective Action Plan.
Finding No. 2022-004: Tracking Federal Grant Funding Coronavirus State and Fiscal Local Recovery Fund (CSLFRF) Responsible Officials: Daniel Ainslie, Finance Director, Dave Yuhas, Deputy Finance Director - Grants/Financial Reporting and Eduardo Lopez - Operations Engineering Manager Corrective Action Plan: The City will implement a process in which CSLFRF reimbursements will be processed and submitted no later than 60 (sixty) days after end of quarter. The Finance depai1ment will review the expenditure allocations on these reimbursements and track the federal, state and loan portions of these reimbursement to ensure each area is tracked and report correctly. Anticipated Completion Date: Quarter ending September 30, 2023
FAC accepted this audit on September 26, 2022 — management decision was due March 26, 2023.
FAC accepted this audit on September 21, 2021 — management decision was due March 21, 2022.
FAC accepted this audit on September 17, 2020 — management decision was due March 17, 2021.
Federal Programs Affected: Federal Transit Cluster (CFDA #20.507) Compliance Requirement: Suspension and Debarment Questioned Costs: None Condition and Cause: The City does not have an internal control process in place to meet the compliance requirements of suspension and debarment related to vendors the City utilizes in multiple departments of the City. Expenditures to such vendors are allocated to federal programs. Actual vendors charged to the major federal program were not suspended or debarred. Criteria and Effect: Recipients of federal grants are prohibited from contracting with or making sub-awards under covered transactions to parties suspended or debarred. ?Covered transactions? include those contracts for goods or services awarded under a non-procurement transaction (e.g. grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other specified criteria. The recipient of federal grants must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with the entity. The lack of adequate internal controls over suspension and debarment could result in the City making payments to an ineligible party, which could result in noncompliance with federal requirements. Recommendation: The City should adopt a policy for vendors involved in transactions throughout multiple departments of the City to verify covered transactions do not transpire with suspended or debarred parties prior to any goods being purchased or services being provided. Repeat Finding from Prior Year: Yes, prior year finding 2018-004. Response/Corrective Action Plan: The City agrees with the above finding. See City?s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Programs Affected: Federal Transit Cluster (CFDA #20.507) Compliance Requirement: Suspension and Debarment Questioned Costs: None Condition and Cause: The City does not have an internal control process in place to meet the compliance requirements of suspension and debarment related to vendors the City utilizes in multiple departments of the City. Expenditures to such vendors are allocated to federal programs. Actual vendors charged to the major federal program were not suspended or debarred. Criteria and Effect: Recipients of federal grants are prohibited from contracting with or making sub-awards under covered transactions to parties suspended or debarred. ?Covered transactions? include those contracts for goods or services awarded under a non-procurement transaction (e.g. grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other specified criteria. The recipient of federal grants must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with the entity. The lack of adequate internal controls over suspension and debarment could result in the City making payments to an ineligible party, which could result in noncompliance with federal requirements. Recommendation: The City should adopt a policy for vendors involved in transactions throughout multiple departments of the City to verify covered transactions do not transpire with suspended or debarred parties prior to any goods being purchased or services being provided. Repeat Finding from Prior Year: Yes, prior year finding 2018-004. Response/Corrective Action Plan: The City agrees with the above finding. See City?s Corrective Action Plan.
Responsible Officials: Pauline Sumption, Finance Officer Corrective Action Plan: Changes to the City's Uniform Grant Guidance Policies/Procedures that specifically address Suspension and Debarment were adopted in the fall of 2019. Unfortunately, the implementation of the corrective action plan was not completed for many of the City's 11,000 plus existing vendors by December 31, 2019. The Finance Office has implemented a procedure to ensure compliance for all new vendors. Program directors will be responsible for the implementation of Suspension and Debarment procedures as it relates to existing vendors for their specific federal program by the end of fiscal year 2020. Anticipated Completion Date: Program directors will ensure compliance for those programs receiving federal funds by December 31, 2020.
2018-004
Federal Programs Affected: Federal Transit Cluster (CFDA #20.507) Compliance Requirement: Allowable Costs/Activities Allowed Questioned Costs: None Condition and Cause: Transit employees filling in as temporary supervisors were paid a higher rate than the documented rate in their signed contracts. Criteria and Effect: Employees who are not paid in accordance with their signed contracts could result in noncompliance with federal requirements. Recommendation: The City should pay all employees in accordance with their signed contracts. Repeat Finding from Prior Year: Yes, prior year finding 2018-005. Response/Corrective Action Plan: The City agrees with the above finding. See City?s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Programs Affected: Federal Transit Cluster (CFDA #20.507) Compliance Requirement: Allowable Costs/Activities Allowed Questioned Costs: None Condition and Cause: Transit employees filling in as temporary supervisors were paid a higher rate than the documented rate in their signed contracts. Criteria and Effect: Employees who are not paid in accordance with their signed contracts could result in noncompliance with federal requirements. Recommendation: The City should pay all employees in accordance with their signed contracts. Repeat Finding from Prior Year: Yes, prior year finding 2018-005. Response/Corrective Action Plan: The City agrees with the above finding. See City?s Corrective Action Plan.
Responsible Officials: Pauline Sumption, Finance Officer Corrective Action Plan: The current AFSCME contract under consideration contains language for out of class pay that will pay all fill-in supervisors at the same contracted rate. Anticipated Completion Date: Changes to the AFSCME contract are currently on schedule to be adopted before December 31. 2020.
2018-005
Federal Programs Affected: Federal Transit Cluster (CFDA #20.507) Compliance Requirement: Period of Performance Questioned Costs: None Condition and Cause: The City expended funds from a Federal Transit grant in 2019 outside the allowed period of performance. No extension was requested or received from the Department of Transportation. Criteria and Effect: The City?s Federal Transit Grant SD-2017-008-00 had a period of performance through September 30, 2018. Federal expenditures outside the period of performance could result in questioned costs. The Department of Transportation reimbursed the expenditures outside of the period of performance. Recommendation: Federal expenditures should incurred during the period of performance or an extension should be requested from awarding agencies. Repeat Finding from Prior Year: Not Applicable Response/Corrective Action Plan: The City agrees with the above finding. See City?s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Programs Affected: Federal Transit Cluster (CFDA #20.507) Compliance Requirement: Period of Performance Questioned Costs: None Condition and Cause: The City expended funds from a Federal Transit grant in 2019 outside the allowed period of performance. No extension was requested or received from the Department of Transportation. Criteria and Effect: The City?s Federal Transit Grant SD-2017-008-00 had a period of performance through September 30, 2018. Federal expenditures outside the period of performance could result in questioned costs. The Department of Transportation reimbursed the expenditures outside of the period of performance. Recommendation: Federal expenditures should incurred during the period of performance or an extension should be requested from awarding agencies. Repeat Finding from Prior Year: Not Applicable Response/Corrective Action Plan: The City agrees with the above finding. See City?s Corrective Action Plan.
Responsible Officials: Megan Gould, Rapid Transit Director Corrective Action Plan: The Rapid Transit Director will verify that monthly expenditure reimbursement requests fall within the period of performance dates of the applicable grant being drawn against. Anticipated Completion Date: This corrective action plan has been implemented.
FAC accepted this audit on September 27, 2019 — management decision was due March 27, 2020.
GSA_MIGRATION
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GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on September 24, 2018 — management decision was due March 24, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on April 1, 2018 — management decision was due October 1, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2015-005
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