City of Fort LauderdaleLocal Government

Condition: In accordance with 2 CFR-200.328 and 2 CFR-200.303, non-federal entities must submit performance and financial reports as required by the awarding agency and must establish and maintain effective internal control over compliance with federal statutes, regulations, and the terms and conditions of the federal award. Context: The City is required to submit monthly progress reports ten calendar days after the end of each month, quarterly progress reports no later than the 10th of quarter end, and a bi-annual Contract and Subcontract Activity form (HUD-2516), to be submitted by April 15 and October 15 each year. Per testing, monthly and quarterly reports were submitted 10 to 27 days after the deadline. ABPA was unable to obtain evidence that form HUD-2516 was submitted by either of the required due dates. Effect: Failure to submit required reports in a timely manner, and the lack of supporting documentation, represents a deficiency in internal control over compliance. This increases the risk of noncompliance with federal reporting requirements, which could result in questioned costs, delayed reimbursements, or jeopardize future funding. Cause: Delays in report submission were primarily due to insufficient internal controls over the reporting process, lack of clear assignment of responsibilities, and inadequate monitoring of reporting deadlines. Questioned costs: None. Recommendation: We recommend that the City strengthen its internal controls over compliance by implementing a centralized reporting calendar or system to monitor federal reporting deadlines. In addition, procedures should be established to ensure that documentation of timely report submission is retained in the grant files. Staff responsible for grant administration should also receive training on federal reporting requirements.

Condition: The City did not provide evidence demonstrating that the required monthly, quarterly, and biannual reports were submitted in accordance with the timelines specified in the federal award requirements. The City is required to comply with the reporting requirements established by the grant agreement or the applicable provisions of the OMB Compliance Supplement. Context: The City is required to submit monthly progress reports ten calendar days after the end of each month, quarterly progress reports no later than the 10th of quarter end, and a bi-annual Contract and Subcontract Activity form (HUD-2516), to be submitted by April 15 and October 15 each year. Per testing, monthly and quarterly reports were submitted 10 to 27 days after the deadline. ABPA was unable to obtain evidence that form HUD-2516 was submitted by either of the required due dates. Effect: Failure to submit required reports in a timely manner, and the lack of supporting documentation, represents a deficiency in internal control over compliance. This increases the risk of noncompliance with federal reporting requirements, which could result in questioned costs, delayed reimbursements, or jeopardize future funding. Cause: Delays in report submission were primarily due to insufficient internal controls over the reporting process, lack of clear assignment of responsibilities, and inadequate monitoring of reporting deadlines. Questioned costs: None. Recommendation: We recommend that the City strengthen its internal controls over compliance by implementing a centralized reporting calendar or system to monitor federal reporting deadlines. In addition, procedures should be established to ensure that documentation of timely report submission is retained in the grant files. Staff responsible for grant administration should also receive training on federal reporting requirements.

Reporting - 21.027 - Coronavirus State and Local Fiscal Recovery Fund Condition: The City could not provide evidence of timely reporting of the required quarterly progress reports. Effect: The City is not in compliance with the grant terms. Cause: Staff responsible for completing the reporting was no longer with the organization and due to displacement from the natural disaster timely reporting was impacted. Questioned Costs: None Recommendation: A review of the grant agreement and terms with the grant manager/project led to ensure that all requirement(s) are understood and to provide guidance on reporting requirements and resources.

Reporting - 97.067 - Homeland Security Condition: The City could not provide evidence of timely reporting of the required quarterly progress reports. Context: The City is required to submit quarterly progress reports by the end of the month after the quarter’s end. Per testing the third and fourth quarters’ reports were submitted after this deadline by 8 months and 4 months respectively, therefore, they are deemed not in compliance. Effect: The City is not in compliance with the grant terms and therefore funding may be jeopardized. Cause: Staff responsible for completing the reporting was new to this process and was not aware of the requirement deadline. Questioned Costs: None Recommendation: A review of the grant agreement and terms with the grant manager/project led to ensure that all requirement(s) are understood and to provide guidance on reporting requirements and resources.

2022-001 ? Reporting ? 20.106 Airport Improvements Condition: The City could not provide documentation that SF-425, Federal Financial Report was completed and submitted annually as required by the Compliance Supplement. Context: The City is required to perform task in noted areas to be in compliance with the grant terms. For this program annual reporting was a compliance requirement, through submission of the SF-425, Federal Financial Report. The Airport was unaware that this compliance requirement was to be fulfilled by them, therefore, the report was not filed deeming them not in compliance. Effect: The City is not in compliance with the grant terms and therefore funding may be jeopardized. Cause: Staff responsible for completing the reporting were not aware of the requirement and/or that it was their responsibility to complete the task. Questioned Costs: None Recommendation: A review of the grant agreement and terms with the grant manager/project led to ensure that all requirement(s) are understood and to whom is responsible to complete the task.

2022-002 Eligibility ? 14.241 HOPWA Condition: The City could not validate the income used in determining eligibility for services of HOPWA funds documented in the Provide Enterprise (PE) System. In addition, income verification support was inconsistent with monthly income amount noted and there was evidence of instances where the monthly support provided was not for a consecutive 3-month period, as required for income verification. Furthermore, self-verification was used to verify income after the COVID-19 restriction was lifted. Context: The participant?s information is initially inputted by the agency (sub-recipient) and submitted to the City for review and approval of funding for housing. For case management, the agency (sub-recipient) input an intake form which includes income, proof of status and identification is reviewed during the annual monitoring process completed by the City. The participant file should include the application information entered and scans of supporting documentation. The PE system does limitations of storage capacity therefore the original hard copies are kept at the agency site and provided upon request. Effect: The City may not be in compliance with the programs eligibility criteria and funding may be jeopardized. Cause: The subrecipients procedure are not conducive to ensure proper income verification of program participants. The City must also increase monitoring of files and perform additional procedures to address known risk with identified subrecipient(s) and/or process(es). Questioned Costs: Undetermined Recommendation: To increase the sample population and frequency of testing of the participant case files to ensure that the program guidelines are being met. Increase the frequency of the subrecipient monitoring and the perform follow-up of noted monitoring findings within prior to traditional annual monitoring. In addition, to provide continual training to the subrecipients and perform assessment of efficiencies of procedures to determine viability of relationship.

Finding 2021-002 - Sub-Recipient Monitoring - Significant Deficiency Assistance Listing Number - 14.239 U.S. Department of Housing and Urban Development HOME Investment Partnership Program Criteria or specific requirement: Internal control should be in place to ensure that information submitted by the Sub-Recipient is reviewed by the City and that the review is documented. Condition: The City could not provide documentation that the Single Audit Report for the Sub-Recipient of the City was reviewed by appropriate personnel of the City. Context: The City requires that their Sub-Recipient provide a Single Audit Report on an annual basis. The City was able to provide the completed Single Audit Report of the Sub-Recipient but was unable to provide documentation that the City reviewed the Single Audit Report to determine if the Sub-Recipient had any findings and/or questioned costs in the Single Audit Report. Effect: The Sub-Recipient could have had findings and/or questioned costs and the City would be unaware of the findings and/or questioned costs. Cause: Staff responsible for receiving and reviewing the Sub-Recipient's Single Audit Report separated from the City and the current staff could not locate evidence of receipt or review. Questioned Costs: None Recommendation: Crowe recommends the City implement effective internal control to ensure the Sub- Recipients Single Audit Report is reviewed and that the review is documented.