City of Cape CoralLocal Government

2023-002 Reporting Federal Agency: U.S Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year: SLFRP1761 2021 Assistance Listing Number: 21.027 Award Period: March 3, 2021, through December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of monitoring and reporting program performance. Metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding are required to submit quarterly Project and Expenditure Reports that cover one calendar quarter and must be submitted to Treasury by the last day of the month following the end of the period covered. Condition: Quarterly Project and Expenditure Reports were not submitted timely, within 30 days of period end to the U.S. Department of Treasury, as required. Questioned Costs: None Context: During our testing, we reviewed all four Quarterly Project and Expenditure for the period. We noted that two of four Quarterly Project and Expenditure Reports reviewed were not submitted within 30 days of period end, as required. Cause: Policies and procedures were not established to ensure the timely filing of reports. Repeat Finding: No Effect: The City was not in compliance with the reporting requirements as specified in the grant agreement. Recommendation: We recommend that the City design processes and procedures to ensure that all reports are submitted timely as required by grant agreements. We recommend the City develop an internal compliance checklist that includes required reports and due dates to be maintained for tracking and record keeping purposes to assist in monitoring compliance. Views of responsible officials: Management agrees with the above finding and recommendation. However, as a checklist is already in place, the City will evaluate and work with the Department of Treasury for ways to overcome the technical issues encountered, and acknowledged by the Department, that restricts the filing of reports in a timely manner and will continue to closely monitor the quarterly filings with the Department.

2022-003 Reporting Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Community Development Block Grant Federal Award Identification Number and Year: B21MC120027, various Assistance Listing Number: 14.218 Grant Award Number: B21MC120027 Award Period: October 1, 2021 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of monitoring and reporting program performance. Entities receiving CDBG or CDBG-CV funding are required to submit the IDIS PR-29 Cash on Hand Quarterly Report every quarter, within 30 days of the end of the quarter. Additionally, entities receiving NSP-1 or NSP-3 funding are required to submit each quarter the Quarterly Performance Report. Condition: CDBG and CDBG-CV Cash on Hand Quarterly Reports were not submitted timely, within 30 days of period end to the U.S. Department of Housing and Urban Development, as required. Questioned Costs: None Context: During our testing, we reviewed all four quarterly CDBG Cash on Hand Quarterly Reports and all four quarterly CDBG-CV Cash on Hand Quarterly Reports. We also reviewed all four Quarterly Performance Reports for NSP-1 and NSP-3 program for the period. We noted that all CDBG Cash on Hand Quarterly Reports and CDBG-CV Cash on Hand Quarterly Reports reviewed were not submitted within 30 days of period end, as required. The fourth quarter Cash On Hand reports were not submitted to date at the time of review. We also noted all four Quarterly Performance Reports for NSP-1 and NSP-3 were not submitted timely within 30 days of period end, as required, with three of the four reports unsubmitted at the time of review. Cause: Policies and procedures were not established to ensure the timely filing of reports. Repeat Finding: No Effect: The City was not in compliance with the reporting requirements as specified in the grant agreement. Recommendation: We recommend that the City design processes and procedures to ensure that all reports are submitted timely as required by grant agreements. We recommend the City develop an internal compliance checklist that includes required reports and due dates to be maintained for tracking and record keeping purposes to assist in monitoring compliance. Views of responsible officials: For a period of time, City staff could not access the federal system, however, this issue has since been resolved. Finance will keep a calendar of all reporting deadlines and follow up with responsible departments prior to the due date to ensure reports are submitted on time.

2022-004 Allowable Costs, Activities and Period of Performance Federal Agency: U.S Department of Housing and Urban Development Federal Program Name: Community Development Block Grant Assistance Listing Number: 14.218 Federal Award Identification Number and Year: B21MC120027, various Award Period: October 1, 2021 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria: The contract award start date is October 1, 2021. Expenditures incurred prior to the contract start date are not eligible for reimbursement under this contract agreement. Condition: Expenditures incurred prior to the grant contract?s period of performance per the contract agreement were improperly charged to the grant prior to the contract?s stated start date of October 1, 2021. Questioned Costs: None Context: Our sample of four transactions during the first month of the contract period identified one transaction in the amount of $101 charged to the program outside of the period of performance. Cause: The City?s internal controls did not prevent or detect the error. Repeat Finding: No Effect: The City was not in compliance with period of performance requirements as specified in the grant agreement. Recommendation: We recommend the City establish procedures for the accrual of grant-related reimbursements to ensure expenditures are invoiced within the appropriate contract dates as specified by the agreements. Views of responsible officials: Management will ensure that grant expenditures processed after the end of the fiscal year are thoroughly reviewed to ensure they are recorded in the correct fiscal year.

2020-004 Subrecipient Monitoring Federal Agency: U.S Department of Housing and Urban Development Federal Program Title: Community Development Block Grant CFDA Number: 14.218 Award Period: October 1, 2019 through September 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Financial Reporting, Other Matter Criteria: CFR ?200.331 Requirements for pass-through entities requires that each pass-through entity must clearly identify and communicate certain information related to the subaward to subrecipient entities. Condition: During our testing, we noted that the City did not communicate all required information of CFR ?200.331 to a subrecipient entity. Questioned Costs: None Context: The City failed to communicate all the required information of CFR ?200.331 to one subrecipient. Cause: The City correctly used a developer agreement as required by HUD, but did not make supplemental communication to the developer once the City determined them to be a subrecipient. Repeat Finding: No Effect: The subrecipient may not be informed of all of their obligations as a subrecipient required under the grant. Recommendation: We recommend that the City design processes and procedures to ensure that all entities that the City considers to be a subrecipient execute agreements containing the necessary items as required by the Uniform Guidance and that a standard contract be created that contains all the required information. Views of responsible officials and planned corrective actions: We intend to include in a proposed grant administration policy, a requirement to summarize this information in a one-page document that will be transmitted to a sub-recipient or vendor, as necessary.

2020-005 Reporting Federal Agency: U.S Department of Housing and Urban Development Federal Program Title: Community Development Block Grant CFDA Number: 14.218 Award Period: October 1, 2019 through September 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Financial Reporting, Other Matter Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of monitoring and reporting program performance. Condition: During our testing, we noted that the City?s quarterly financial reports were not filed with the U.S. Department of Housing and Urban Development. Questioned Costs: None Context: The City failed to complete and file the required reports during 2020. Cause: The City did not adjust their policies and procedures when the U.S. Department of Housing and Urban Development changed their reporting requirements for fiscal year 2020, and the City was unaware that reports were required to be filed. Repeat Finding: No Effect: The City was not in compliance with reporting requirements of the grant agreement. Recommendation: We recommend that the City design controls to ensure that all reporting requirements are followed and review and approval is sufficiently performed prior to submission. Views of responsible officials and planned corrective actions: The City has implemented procedures to ensure that quarterly reports are filed within the timeframe required.

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