CITY OF JACKSONVILLE, FLORIDA

2024-002 – COVID 19: Community Development Block Grants/Entitlement Grants Federal Awarding Agency – U.S. Department of Housing and Urban Development Assistance Listing Number – 14.218 FAIN – B-23-UC-12-0017 Award Year – 2023 Questioned costs – none Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, period of performance, and special tests and provisions – wage rate requirements. The related compliance requirements are set in 24 CFR Part 570 Subpart D and sections 570.200 through .710, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the April 30, 2021 Quick Guide, CDBG-CV PPR Tieback Flexibilities, Title I of the Housing Community Development Act (HCDA) of 1974, as amended (Pub. L. No. 93-383) (42 USC 5301), 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), 31 USC 1552, Section III.B.7 of CDBG-CV Notice, Section 110(a) of the HCD Act, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of one invoice for a payment to a subrecipient, did not have evidence of all required approvals necessary to ensure compliance with allowable costs, cost principles, and period of performance requirements. One monthly payroll allocation journal entry did not have evidence of required approval necessary to ensure compliance with allowable costs, cost principles, and period of performance requirements. Controls were not sufficient over the special tests and provisions – wage rate requirements compliance requirement. Cause: Internal controls over certain payments, including payments requiring review of contractor and subcontractor wage rates were not evidenced with clear documentation. Effect: Allowable costs, cost principles, period of performance, and special tests and provisions – wage rate requirements compliance requirements may not be met due to lack of reperformable internal controls. Recommendation: We recommend that the City ensure wage rate requirement compliance is prioritized when applicable. We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

2023-002 – COVID 19: Community Development Block Grants/Entitlement Grants Federal Awarding Agency – U.S. Department of Housing and Urban Development Assistance Listing Number – 14.218 FAIN – B-20-UW-12-0017 & B-21-UC-12-0017 Award Year – 2021 & 2022 Questioned costs – none Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, period of performance, and special tests and provisions – wage rate requirements. The related compliance requirements are set in 24 CFR Part 570 Subpart D and sections 570.200 through .710, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the April 30, 2021 Quick Guide, CDBG-CV PPR Tieback Flexibilities, Title I of the Housing Community Development Act (HCDA) of 1974, as amended (Pub. L. No. 93-383) (42 USC 5301), 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), 31 USC 1552, Section III.B.7 of CDBG-CV Notice, Section 110(a) of the HCD Act, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of certain invoices, including construction payments and payments to subrecipients, did not have evidence of all required approvals necessary to ensure compliance with allowable costs, cost principles, and period of performance requirements or such approvals were not documented in a manner that is reperformable. Weekly payroll reports were not reviewed as part of the special tests and provisions – wage rate requirements compliance requirement, resulting in material noncompliance. Cause: Internal controls over certain payments, including payments requiring review of contractor and subcontractor wage rates were not evidenced with clear documentation. Effect: Allowable costs, cost principles, and period of performance compliance requirements may not be met due to lack of reperformable internal controls. Wage rate requirements were not complied with. Recommendation: We recommend that the City ensure wage rate requirement compliance is prioritized when applicable. We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

2023-003 – COVID 19: Coronavirus State and Local Fiscal Recovery Funds Federal Awarding Agency – U.S. Department of the Treasury Assistance Listing Number – 21.027 FAIN – n/a Award Year – 2021 Questioned costs – none Criteria: 2 CFR Part 200 in general and 2 CFR sections 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, and earmarking. The related compliance requirements are set in 2 CFR Part 200 sections 200.514(c), 200.212, 200.318(h), 200.332, 180.300 and subpart E; 48 CFR section 52.209-6; 31 CFR section 19.300; sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 as codified at 42 USC 802 and 803 and 31 CFR Part 35, federal awarding agency regulations, and the terms and conditions of the award. Condition: Controls related to calculation and reporting of lost revenue were not effective and the amount calculated as base year revenue was incorrectly reported. Cause: Base year calculation of revenue was performed using interim financial information and was not reconciled to final audited reports. Base year calculation of revenue was not clearly documented. Subsequent year revenue calculations were performed by a consultant who was not engaged to review the base year calculation. Controls over such calculations were not effective. Effect: Calculation of lost revenue was incorrectly reported. Expenditures related to the provision of government services related to such lost revenue did not exceed the actual lost revenue. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR Part 200 in general and 2 CFR section 200.332 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, beneficiary eligibility, period of performance, reporting, subrecipient monitoring, and special tests and provisions. The related compliance requirements are set in Section 501 of Division N of the Consolidated Appropriations Act, 2021, 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), federal awarding agency regulations, and the terms and conditions of the award. Condition: Subrecipient monitoring controls related to periodic subrecipient reports and the final subrecipient expenditure reports, financial reporting, period of performance, and special tests and provisions for funding reallocations were not documented in a manner that is reperformable. Cause: Control activities were performed informally and without clear documentation. Effect: Individuals who are not eligible to receive the services funded by this grant may incorrectly be served by the subrecipient entities, allowable costs or cost principles may not have been followed by subrecipient entities, or subrecipients may not have been properly monitored for other compliance requirements. Expenditures could be made outside of the period of performance, amounts in the financial reports could be incorrect, funding reallocation requirements could be missed. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR Part 200 in general and 2 CFR section 200.332 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, reporting, and suspension and debarment. The related compliance requirements are set in 2 CFR Part 200 sections 200.514(c), 200.212, 200.318(h), 180.300 and subpart E; 48 CFR section 52.209-6; 31 CFR section 19.300; sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 as codified at 42 USC 802 and 803 and 31 CFR Part 35, federal awarding agency regulations, and the terms and conditions of the award. Condition: Controls related to calculation and reporting of lost revenue were not effective and the amount calculated as base year revenue was incorrectly reported. Controls related to reporting of other grant expenditures were not effective and certain amounts were missing from the financial reports. Controls related to ensuring contractors were not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 were not documented in a manner that is reperformable. Cause: Base year calculation of revenue was performed using interim financial information and was not reconciled to final audited reports. Base year calculation of revenue was not clearly documented. Subsequent year revenue calculations were performed by a consultant who was not engaged to review the base year calculation. Controls over such calculations were not effective. Review of financial reports was not sufficient to ensure all grant expenditures were reported. Suspension and debarment controls were not evidenced with clear documentation; checklists are maintained but were not completed in all cases. Effect: Calculation of lost revenue was incorrectly reported. Expenditures related to the provision of government services related to such lost revenue did not exceed the actual lost revenue. Certain other grant expenditures were erroneously excluded from the financial reports. Procurement of contractors risks including those who were suspended or debarred; however none such were identified. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, and matching. The related compliance requirements are set in 2 CFR sections 200.330, .331, .501(h), .514(c), and subpart E, 24 CFR Part 576, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of monthly subrecipient reports to ensure compliance with allowable costs, cost principles, and matching requirements were not documented in a manner that is reperformable. Timesheet approvals were not documented in all instances to ensure compliance with allowable costs, cost principles. Cause: Internal controls over monthly subrecipient report review for allowable costs, cost principles, and matching compliance requirements and timesheet reviews and approvals were not evidenced with clear documentation. Effect: Subrecipients may not have met required matching compliance requirements. Time could be charged to the grant that is not allowable. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, period of performance, reporting, and special tests and provisions ? wage rate requirements. The related compliance requirements are set in 24 CFR Part 570 Subpart D and sections 570.200 through .710, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the April 30, 2021 Quick Guide, CDBG-CV PPR Tieback Flexibilities, Title I of the Housing Community Development Act (HCDA) of 1974, as amended (Pub. L. No. 93-383) (42 USC 5301), 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), 31 USC 1552, Section III.B.7 of CDBG-CV Notice, Section 110(a) of the HCD Act, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of financial reports to ensure compliance with allowable costs, cost principles, period of performance, and reporting requirements were not documented in a manner that is reperformable. Weekly payroll reports were not reviewed as part of the special tests and provisions ? wage rate requirements compliance requirement, resulting in material noncompliance. Cause: Internal controls over financial reports were not evidenced with clear documentation. Effect: Financial reports may not be accurate, allowable costs, cost principles, and period of performance compliance requirements may not be met due to lack of reperformable internal controls. Wage rate requirements were not complied with. Recommendation: We recommend that the City ensure wage rate requirement compliance is prioritized when applicable. We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, cash management, period of performance, matching, and reporting. The related compliance requirements are set in 24 CFR Part 570 Subparts D and E, Appendices III-V11, and sections 200.330, .331, and .501(h), the Omnibus Crime Control and Safe Streets Act of 1968 as amended by the Violent Crime Control and Law Enforcement Act of 1994, Title I, Part Q, Pub. L. No. 103-322, 34 USC 10381 et seq., federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of financial and drawdown reports to ensure compliance with reporting requirements which also covers allowable costs, cost principles, cash management, period of performance, and matching requirements were not documented in a manner that is reperformable. No internal controls were identified related to review of progress reports to ensure compliance with reporting requirements. Cause: Internal controls over financial, drawdown, and progress reports were not evidenced with clear documentation. Effect: Financial reports may not be accurate; allowable costs, cost principles, cash management, period of performance, matching, and reporting compliance requirements may not be met due to lack of reperformable internal controls. Progress reports may not be accurate. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, cash management, matching/level of effort, and reporting. The related compliance requirements are set in 24 CFR Part 570 Subparts D and E, Appendices III-V11, and sections 200.330, .331, and .501(h), Section 34 of the Federal Fire Prevention and Control Act of 1974, Pub. L. No. 93-498, as amended (15 USC Sec. 2229a) and Section 4013 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2, federal awarding agency regulations, and the terms and conditions of the award. Condition: Internal controls related to review of drawdown reports to ensure compliance with reporting requirements which also covers allowable costs, cost principles, cash management, and matching requirements were not documented in a manner that is reperformable. No internal controls were identified related to review of progress reports to ensure compliance with reporting requirements. No internal controls were identified related to the level of effort requirement. Cause: Internal controls related to review of drawdown reports, progress reports, and level of effort were not evidenced with clear documentation. Effect: Financial reports may not be accurate; allowable costs, cost principles, cash management, level of effort, matching, and reporting compliance requirements may not be met due to lack of reperformable internal controls. Progress reports may not be accurate. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR Part 200 in general and 2 CFR section 200.332 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, beneficiary eligibility, and subrecipient monitoring. Condition: Subrecipient monitoring controls related to monthly subrecipient reports and the final subrecipient expenditure reports were not documented in a manner that is reperformable. Cause: The program was new and controls were done verbally and without clear documentation. Effect: Individuals who are not eligible to receive the services funded by this grant may incorrectly be served by the subrecipient entities, allowable costs or cost principles may not have been followed by subrecipient entities, or subrecipients may not have been properly monitored for other compliance requirements. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR Part 200 in general and 2 CFR section 200.332 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for beneficiary eligibility and subrecipient monitoring. Condition: Subrecipient monitoring controls related to review of monthly subrecipient reports and annual subrecipient financial statements were not documented in a manner that is reperformable. Cause: Subrecipient monitoring controls were not evidenced with clear documentation. Effect: Individuals who are not eligible to receive the services funded by this grant may incorrectly be served by the subrecipient entities or subrecipients may not have been properly monitored for other compliance requirements. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR Part 200 in general and 2 CFR section 200.306 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for matching. Condition: Internal controls related to review of monthly subrecipient reports to ensure compliance with matching requirements were not documented in a manner that is reperformable. Cause: Internal controls over monthly subrecipient report review for matching compliance were not evidenced with clear documentation. Effect: Subrecipients may not have met required matching compliance requirements. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.

Criteria: 2 CFR 200.303 requires non?Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for beneficiary eligibility contained in 45 CFR Parts 260 through 265. Condition: Eligibility controls were not being performed throughout the full year. Cause: The program is rebuilding after turnover in providers and the necessary hiring and training of new Family Support Workers. Effect: Individuals who are not eligible to receive the services funded by this grant may incorrectly be served. Recommendation: We recommend that Healthy Families Jacksonville reintroduce the control which was partially in effect during the year and ensure that it is performed consistently each month. Views of responsible officials: We agree with the recommendation and the controls are now in place and results are expected to be much improved in FY2020 reporting and compliance.The current monitoring process by the KHA Quality & Compliance Supervisor is an internal policy and is not required by the grant. This policy states that at least one file for each Family Support Worker will be reviewed quarterly to review compliance on items that include eligibility. Because of an insufficient level of performance by the sub?recipient, there was an emphasis last year on creating on conducting an Efficacy Study of the program and on creating an RFP. These tasks took priority during some time periods as they were necessary to ensure continued quality improvement for the program.

Criteria: 2 CFR 200.303 requires non?Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for Maintenance of Effort contained in 45 CFR Parts 260 through 265.Healthy Families Jacksonville is responsible for maintaining controls over the Level of Effort compliance requirement. Condition: Maintenance of Effort monitoring controls over Healthy Families Jacksonville could not be evidenced. Cause: The program is rebuilding after turnover in providers and the necessary hiring and training of new Family Support Workers. Effect: Families may not be receiving the services that Healthy Families Florida has contracted with Healthy Families Jacksonville to provide. Recommendation: We recommend that Healthy Families Jacksonville continue to work closely with the Healthy Families Florida Director to make decisions necessary to bring the level of program services into compliance. Views of responsible officials: We agree with the recommendation continue to improve the monitoring and the implementation of improved processes.The current monitoring process by the KHA Quality & Compliance Supervisor is an internal policy and is not required by the grant. This policy states that at least one file for each Family Support Worker will be reviewed quarterly to review compliance on all contract and model related items. Because of an insufficient level of performance by the sub?recipient, there was an emphasis last year on creating on conducting an Efficacy Study of the program and on creating an RFP. These tasks took priority during some time periods as they were necessary to ensure continued quality improvement for the program.

Criteria: 2 CFR 200.303 requires non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for beneficiary eligibility contained in 45 CFR Parts 260 through 265. Condition: Eligibility controls were not being performed throughout the full year. Cause: The program is rebuilding after turnover in providers and the necessary hiring and training of new Family Support Workers. Effect: Individuals who are not eligible to receive the services funded by this grant may incorrectly be served. Recommendation: We recommend that Healthy Families Jacksonville reintroduce the control which was partially in effect during the year and ensure that it is performed consistently each month. Views of responsible officials: We agree with the recommendation and the controls are now in place and results are expected to be much improved in FY2020 reporting and compliance. The current monitoring process by the KHA Quality & Compliance Supervisor is an internal policy and is not required by the grant. This policy states that at least one file for each Family Support Worker will be reviewed quarterly to review compliance on items that include eligibility. Because of an insufficient level of performance by the sub-recipient, there was an emphasis last year on creating on conducting an Efficacy Study of the program and on creating an RFP. These tasks took priority during some time periods as they were necessary to ensure continued quality improvement for the program.

Criteria: 2 CFR 200.303 requires non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for Maintenance of Effort contained in 45 CFR Parts 260 through 265. Healthy Families Jacksonville is responsible for maintaining controls over the Level of Effort compliance requirement. Condition: Maintenance of Effort monitoring controls over Healthy Families Jacksonville could not be evidenced. Cause: The program is rebuilding after turnover in providers and the necessary hiring and training of new Family Support Workers. Effect: Families may not be receiving the services that Healthy Families Florida has contracted with Healthy Families Jacksonville to provide. Recommendation: We recommend that Healthy Families Jacksonville continue to work closely with the Healthy Families Florida Director to make decisions necessary to bring the level of program services into compliance. Views of responsible officials: We agree with the recommendation continue to improve the monitoring and the implementation of improved processes. The current monitoring process by the KHA Quality & Compliance Supervisor is an internal policy and is not required by the grant. This policy states that at least one file for each Family Support Worker will be reviewed quarterly to review compliance on all contract and model related items. Because of an insufficient level of performance by the sub-recipient, there was an emphasis last year on creating on conducting an Efficacy Study of the program and on creating an RFP. These tasks took priority during some time periods as they were necessary to ensure continued quality improvement for the program.

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