City of Sebastian FloridaLocal Government

Program title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds COVID-19 Airport Improvement Program Assistance Listing Numbers: 21.027 20.106 Federal Award ID Number: SLFRP0894, 23PLN17 3-12-0145-012-2023, 3-12-0145-017-2021 Name of Federal Agency: United States Department of Treasury - Award 23PLN17 Passed through the Florida Department of Environmental Protection; Federal Aviation Authority Funding: 2024 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. The grant agreements required various performance/reimbursement/financial reports. The reports were not reviewed prior to submission to granting agency. A Quarterly report required for the Federal Aviation Authority was not submitted within the 30 days after quarter close. Condition: During the audit, it was identified that required reports were not reviewed prior to submission. Reports were submitted, but there was no documented evidence of thorough review or oversight, leading to concerns regarding the accuracy, completeness, and compliance of the reports. During the audit, it Report 5370 was submitted late. The required due date was within 30 days of quarter close. The report was submitted twenty-two days after due date. Cause: The City was unaware of the requirement that reports be reviewed by a person other than the preparer prior to submission. The City received the invoices for the quarterly reports after the due date, causing a delay in submitting the report. Effect: The absence of regular reviews increases the risk of errors, omissions, or non-compliance with regulatory requirements. This oversight can lead to financial discrepancies, inaccurate reporting and matching amounts, and potential legal or reputational risks. Additionally, failure to review reports may delay the identification of operational issues or inefficiencies. The late submission may cause disruptions in compliance with regulatory timelines, potentially lead to penalties or loss of funding. Questioned Costs: None Perspective: Two of the grants that required reports, both did not have any reports reviewed. CRI tested three of the six required reports. Only one was submitted late. Recommendation: Management should implement a formalized process for reviewing all required reports prior to submission. Management’s Response: Management agrees that all financial data would potentially be more accurate if reviewed by an additional qualified person prior to use. However, limited staff has prevented this from always being practical. In the future, management will seek ways to add more controls to all of our processes, including reviews, to ensure more accurate and reliable data is submitted.

Program title: COVID-19 Coronavirus State and Local Fiscal Recover Funds Assistance Listing Numbers: 21.027 Federal Award ID Number: SLFRP0894, 23PLN17 Name of Federal Agency: United States Department of Treasury - Award 23PLN17 Passed through the Florida Department of Environmental Protection; Funding: 2024 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Vendors should be checked for suspension and debarment prior to services being performed. Condition: During the audit, it was determined that 2 of the 2 vendors selected for projects were not screened against the federal suspension and debarment list prior to award. The vendor was not verified against the System for Award Management (SAM) or other relevant databases to ensure they were not excluded from doing business with the government, as required by federal regulations. Cause: The City was in the process of hiring a new procurement manager and relied on piggybacking on county contracts when selecting vendors. Effect: The failure to check the vendor against suspension and debarment lists exposes the City to the risk of engaging with vendors who may be ineligible to perform work under federally funded programs. This non-compliance could lead to potential financial penalties, legal consequences, and reputational damage, as well as the risk of working with unqualified or non-compliant vendors. Questioned Costs: None Perspective: One hundred percent of the population (2 vendors) was selected for testing. Both vendors were not checked for suspension and debarment. Recommendation: Management should implement a formalized process for checking all vendors prior to work being started on the project. Management’s Response: In January 2024 a Procurement Manager was hired. Procedures were added to ensure that the City will be in compliance with the 2 CFR 200.303 in the future.

Federal Reporting Requirements Finding Type. Immaterial Noncompliance in Internal Control over Compliance (Reporting). Program. Airport Improvements Program; ALN Number 20.106; Award Numbers 3-12-0145-018-2021, 3-12-0145-019-2022, and 3-12-0145-020-2022. Criteria. Recipients of federal awards are required to submit timely and accurate reports to the awarding agency in accordance with federal compliance requirements. Condition. Certain reports required under the provisions of the grant agreement were not filed by the stated due dates. Cause. This condition appears to be the result of a time lag in identifying the annual reporting requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs were required to be questioned as a result of this finding. Recommendation. We recommend the City review the reporting requirements of each grant to ensure compliance. View of Responsible Officials. Management to provide a response.