City of Charleston, South Carolina

2024-001. Reporting AL#: 21.027 Coronavirus State and Local Fiscal Recovery Funds Award Year: 2024 Criteria: Recipients must submit a Project Expenditure Report, on a quarterly basis during the period of performance of the award. The report must be submitted within 30 calendar days of the end of the reporting quarter. Condition: The Project Expenditure Report for Quarter 2 of 2024 (April 1, 2024, through June 30, 2024), was due no later than July 31, 2024. This report was ultimately submitted in August 2024. Context: We addressed the matter with City management who are aware of the reporting requirements. Effect: Failure to properly review and adhere to policies and procedures related to reporting can lead to noncompliance as well as the withholding of future awards. Cause: Management oversight. Recommendation: We recommend the City review and update its policies and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts. Views of Responsible Officials and Planned Corrective Action: We concur with the finding. The City will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts.

Corrective Action Plan: The City of Charleston will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts. Anticipated Completion Date: Fiscal Year 2025

AL#: 14.241 Housing Opportunities for Persons with AIDS Grant Program Award Year: 2023 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109- 282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as “FFATA” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The subawards are required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Applicable subaward obligations/modifications are required to be reported. Condition: FFATA reporting was due no later than March 31, 2023, (for the Charleston County Human Services Commission Subaward) and no later than April 30, 2023, (Pastors Subaward). These two (2) reports were ultimately submitted by the City in June of 2023. The FFATA reporting for the Pastors Subaward did not include a $10,000 contract amendment, this was corrected by amending the report. Context: We addressed the matter with City management who are aware of the reporting requirements. Effect: Failure to properly review and adhere to policies and procedures related to reporting can lead to noncompliance as well as the withholding of future awards and funds drawdowns by the awarding agency. Cause: Management oversight. Recommendation: We recommend the City review and update its policies and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts.

The City of Charleston will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts.

2023-002. Reporting AL#: 11.307 Economic Adjustment Assistance Revolving Loan Funds Program Award Year: 2020 & 1995 Criteria: Recipients must submit a RLF Financial Report (Form ED-209), including a Portfolio Loan List, on a semiannual basis during the period of performance of the award and after the period of performance of the award (during the Revolving Phase). The report must be submitted within 30 calendar days of the midpoint and end of Recipient’s fiscal year. Condition: The ED-209 reports for July 1, 2023, through December 31, 2023, were due no later than January 30, 2024, for both the EDA Legacy and EDA CARES awards. These reports were ultimately submitted by the CLIMB Fund (who is administering the grant for the City) in February 2024. Context: We addressed the matter with City management who are aware of the reporting requirements. Effect: Failure to properly review and adhere to policies and procedures related to reporting can lead to noncompliance as well as the withholding of future awards. Cause: Management oversight. Recommendation: We recommend the City review and update its policies and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts.

The City of Charleston will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts.

Criteria: Section 33 of the Federal Fire Prevention and Control Act of 1974, as amended, and Title III, Division F of the Department of Homeland Security Appropriations Act require program recipients complete and submit various financial and programmatic reports as a condition of award acceptance. Accordingly, the Programmatic Performance Report (PPR) is due to the Department of Homeland Security no later than July 30th (for the period January 1 ? June 30) and no later than January 30th (for the period July 1 ? December 31). Condition: PPRs were due no later than July 30, 2022 (for the period January 1, 2022 ? June 30, 2022) and no later than January 30, 2023 (for the period July 1, 2022 ? December 31, 2022). These two (2) reports were ultimately submitted by the City in May of 2023. Context: We addressed the matter with City management who are aware of the reporting requirements. Effect: Failure to properly review and adhere to policies and procedures related to reporting can lead to noncompliance as well as the withholding of future awards and funds drawdowns by the awarding agency. Cause: Management oversight. Recommendation: We recommend the City review and update its policies and procedures to ensure all required reports are prepared, reviewed, and submitted within the program?s required timeframes. Views of Responsible Officials and Planned Corrective Action: We concur with the finding. The City will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program?s required timeframes.

Corrective Action Plan: The City of Charleston will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program?s required timeframes. Anticipated Completion Date: Fiscal Year 2023