Polk County Board of County Commissioners

EIN: 596000809

UEI: JBN5EHFNGUG9

Data as of August 25, 2026

Polk County Board of County Commissioners11 audit years11 findings4 repeat
11
Audit Years
11
Total Findings
4
Repeat Findings

FY 2024-09-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on April 30, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 30, 2025 (299 days ago).

What is a management decision? →
2024-001
Reporting
REPEAT

Certain reports reviewed had errors in the reporting as noted below: Number of Exceptions Noted Items Number of Error Tested Exceptions Rate Untimely submission of quarterly reports 8 1 13% Project expenditures were incorrectly stated, and no adequate 8 2 25% documentation was provided. No review performed over the quarterly reports before it is 8 7 88% submitted to Florida Division of Emergencv Management. Close-out reports could not be provided 5 4 80% Questioned costs: N/A Context: The auditors tested 8 quarterly reports and 5 close-out reports. Cause: An adequate review was not being performed over the quarterly reports and monitoring was not being performed over the close-out reports. Effect: Inaccurate reporting can cause the grantee to make inaccurate conclusions regarding the County's grant programs. Failure to complete the close-out report results in projects not being properly approved and closed out. Repeat Finding: Yes Recommendation: It was noted that improvements were observed compared to the previous year, however, we advise the County to maintain a review process to ensure quarterly reports are thoroughly examined before submission to FDEM. Additionally, monitoring procedures should be established to guarantee the proper submission of close-out reports. Implementing a technology solution could aid the grant manager in gathering the necessary reports for the granter, facilitating easier oversight and monitoring of grant compliance. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: Department of Homeland Security Federal Program Name: Hazard Mitigation Grant Assistance Listing Number: 97.039 Federal Award Identification Number and Year: See table below Award Period: See table below Contract Contact Start Contract End Modification Number Date Date End Date #1 H0684 06/29/2022 05/31/2024 N/A H0890 01/20/2023 09/30/2023 12/31/2023 H0892 01/20/2023 09/30/2023 12/31/2023 H0891 01/24/2023 09/30/2023 12/31/2023 H0164 06/08/2019 03/31/2021 01/31/2023 H0165 02/22/2019 07/31/2021 10/31/2023 H0387 05/13/2020 01/31/2021 08/31/2022 H0245 01/14/2020 08/31/2021 10/31/2023 H0341 10/06/2020 01/31/2022 12/31/2023 H0343 07/07/2020 06/30/2021 03/31/2024 H0349 11/17/2020 12/31/2022 04/30/2024 H0510 10/28/2021 04/30/2023 05/31/2024 H0373 04/20/2020 02/28/2022 10/31/2023 H0370 02/19/2020 12/31/2021 10/31/2023 H0488 01/08/2021 11/30/2022 02/09/2024 H0573 01/08/2021 10/31/2023 12/31/2024 Modification Modification End Date #2 End Date #3 N/A N/A 09/30/2024 12/31/2024 09/30/2024 12/31/2024 09/30/2024 12/31/2024 04/30/2024 N/A N/A N/A 04/30/2024 01/31/2026 N/A N/A 09/30/2024 N/A 03/31/2025 N/A 07/31/2024 N/A 12/31/2024 06/30/2025 N/A NA N/A N/A 09/30/2024 N/A N/A N/A Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Consistent with 2 C.F.R. §200.328, the County shall provide the grantee with quarterly reports and a close-out report. These reports shall include the current status and progress by the County and all subcontractors in completing the work described in the County's scope of work. Quarterly reports are due to the grantee no later than fifteen (15) days after the end of each quarter of the program year and shall be sent each quarter until submission of the administrative close-out report. The ending dates for each quarter of the program year are March 31, June 30, September 30, and December 31. The close-out report is due sixty (60) days after termination of this Agreement or sixty (60) days after completion of the activities contained in this Agreement, whichever first occurs. Condition: Certain reports reviewed had errors in the reporting as noted below: Number of Exceptions Noted Items Number of Error Tested Exceptions Rate Untimely submission of quarterly reports 8 1 13% Project expenditures were incorrectly stated, and no adequate 8 2 25% documentation was provided. No review performed over the quarterly reports before it is 8 7 88% submitted to Florida Division of Emergencv Management. Close-out reports could not be provided 5 4 80% Questioned costs: N/A Context: The auditors tested 8 quarterly reports and 5 close-out reports. Cause: An adequate review was not being performed over the quarterly reports and monitoring was not being performed over the close-out reports. Effect: Inaccurate reporting can cause the grantee to make inaccurate conclusions regarding the County's grant programs. Failure to complete the close-out report results in projects not being properly approved and closed out. Repeat Finding: Yes Recommendation: It was noted that improvements were observed compared to the previous year, however, we advise the County to maintain a review process to ensure quarterly reports are thoroughly examined before submission to FDEM. Additionally, monitoring procedures should be established to guarantee the proper submission of close-out reports. Implementing a technology solution could aid the grant manager in gathering the necessary reports for the granter, facilitating easier oversight and monitoring of grant compliance. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Department of Homeland Security Hazard Mitigation Grant-Assistance Listing No. 97.039 Recommendation: It was noted that improvements were observed compared to the previous year, however, we advise the County to maintain a review process to ensure quarterly reports are thoroughly examined before submission to FDEM. Additionally, monitoring procedures should be established to guarantee the proper submission of close-out reports. Implementing a technology solution could aid the grant manager in gathering the necessary reports for the grantor, facilitating easier oversight and monitoring of grant compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will further strengthen oversight of programmatic reporting by developing and implementing a system of monitoring procedures to guarantee that periodic reports contain the appropriate data, have an adequate review performed by the relative Division Director, and are submitted within the timeframe required by the funder. The proper submission of close-out reports will also be accomplished through the developed monitoring procedures. A grant management software will be purchased and implemented and become a foundational component of the County's grant management infrastructure, allowing for more effective oversight by the County grant manager and ensuring greater compliance with all applicable regulations. Additionally, the County will implement mandatory trainings focusing on 2 CFR Part 200, to ensure fiscal and project managers involved with grant projects are fully educated on uniform administrative requirements, including proper reporting and close-out procedures, cost principles, and audit requirements related to federal and pass-through awards. Name(s) of the contact person(s) responsible for corrective action: Terri Saltzman, Grants and Community Investment Manager. Planned completion date for corrective action plan: September 30, 2025. If the Department of Homeland Security has questions regarding this plan, please call Terri Saltzman at 863-519-2049.

Prior Finding References

2023-002

About Reporting →
2024-001
Reporting
REPEAT

Certain reports reviewed had errors in the reporting as noted below: Number of Exceptions Noted Items Number of Error Tested Exceptions Rate Untimely submission of quarterly reports 8 1 13% Project expenditures were incorrectly stated, and no adequate 8 2 25% documentation was provided. No review performed over the quarterly reports before it is 8 7 88% submitted to Florida Division of Emergencv Management. Close-out reports could not be provided 5 4 80% Questioned costs: N/A Context: The auditors tested 8 quarterly reports and 5 close-out reports. Cause: An adequate review was not being performed over the quarterly reports and monitoring was not being performed over the close-out reports. Effect: Inaccurate reporting can cause the grantee to make inaccurate conclusions regarding the County's grant programs. Failure to complete the close-out report results in projects not being properly approved and closed out. Repeat Finding: Yes Recommendation: It was noted that improvements were observed compared to the previous year, however, we advise the County to maintain a review process to ensure quarterly reports are thoroughly examined before submission to FDEM. Additionally, monitoring procedures should be established to guarantee the proper submission of close-out reports. Implementing a technology solution could aid the grant manager in gathering the necessary reports for the granter, facilitating easier oversight and monitoring of grant compliance. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: Department of Homeland Security Federal Program Name: Hazard Mitigation Grant Assistance Listing Number: 97.039 Federal Award Identification Number and Year: See table below Award Period: See table below Contract Contact Start Contract End Modification Number Date Date End Date #1 H0684 06/29/2022 05/31/2024 N/A H0890 01/20/2023 09/30/2023 12/31/2023 H0892 01/20/2023 09/30/2023 12/31/2023 H0891 01/24/2023 09/30/2023 12/31/2023 H0164 06/08/2019 03/31/2021 01/31/2023 H0165 02/22/2019 07/31/2021 10/31/2023 H0387 05/13/2020 01/31/2021 08/31/2022 H0245 01/14/2020 08/31/2021 10/31/2023 H0341 10/06/2020 01/31/2022 12/31/2023 H0343 07/07/2020 06/30/2021 03/31/2024 H0349 11/17/2020 12/31/2022 04/30/2024 H0510 10/28/2021 04/30/2023 05/31/2024 H0373 04/20/2020 02/28/2022 10/31/2023 H0370 02/19/2020 12/31/2021 10/31/2023 H0488 01/08/2021 11/30/2022 02/09/2024 H0573 01/08/2021 10/31/2023 12/31/2024 Modification Modification End Date #2 End Date #3 N/A N/A 09/30/2024 12/31/2024 09/30/2024 12/31/2024 09/30/2024 12/31/2024 04/30/2024 N/A N/A N/A 04/30/2024 01/31/2026 N/A N/A 09/30/2024 N/A 03/31/2025 N/A 07/31/2024 N/A 12/31/2024 06/30/2025 N/A NA N/A N/A 09/30/2024 N/A N/A N/A Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Consistent with 2 C.F.R. §200.328, the County shall provide the grantee with quarterly reports and a close-out report. These reports shall include the current status and progress by the County and all subcontractors in completing the work described in the County's scope of work. Quarterly reports are due to the grantee no later than fifteen (15) days after the end of each quarter of the program year and shall be sent each quarter until submission of the administrative close-out report. The ending dates for each quarter of the program year are March 31, June 30, September 30, and December 31. The close-out report is due sixty (60) days after termination of this Agreement or sixty (60) days after completion of the activities contained in this Agreement, whichever first occurs. Condition: Certain reports reviewed had errors in the reporting as noted below: Number of Exceptions Noted Items Number of Error Tested Exceptions Rate Untimely submission of quarterly reports 8 1 13% Project expenditures were incorrectly stated, and no adequate 8 2 25% documentation was provided. No review performed over the quarterly reports before it is 8 7 88% submitted to Florida Division of Emergencv Management. Close-out reports could not be provided 5 4 80% Questioned costs: N/A Context: The auditors tested 8 quarterly reports and 5 close-out reports. Cause: An adequate review was not being performed over the quarterly reports and monitoring was not being performed over the close-out reports. Effect: Inaccurate reporting can cause the grantee to make inaccurate conclusions regarding the County's grant programs. Failure to complete the close-out report results in projects not being properly approved and closed out. Repeat Finding: Yes Recommendation: It was noted that improvements were observed compared to the previous year, however, we advise the County to maintain a review process to ensure quarterly reports are thoroughly examined before submission to FDEM. Additionally, monitoring procedures should be established to guarantee the proper submission of close-out reports. Implementing a technology solution could aid the grant manager in gathering the necessary reports for the granter, facilitating easier oversight and monitoring of grant compliance. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Department of Homeland Security Hazard Mitigation Grant-Assistance Listing No. 97.039 Recommendation: It was noted that improvements were observed compared to the previous year, however, we advise the County to maintain a review process to ensure quarterly reports are thoroughly examined before submission to FDEM. Additionally, monitoring procedures should be established to guarantee the proper submission of close-out reports. Implementing a technology solution could aid the grant manager in gathering the necessary reports for the grantor, facilitating easier oversight and monitoring of grant compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will further strengthen oversight of programmatic reporting by developing and implementing a system of monitoring procedures to guarantee that periodic reports contain the appropriate data, have an adequate review performed by the relative Division Director, and are submitted within the timeframe required by the funder. The proper submission of close-out reports will also be accomplished through the developed monitoring procedures. A grant management software will be purchased and implemented and become a foundational component of the County's grant management infrastructure, allowing for more effective oversight by the County grant manager and ensuring greater compliance with all applicable regulations. Additionally, the County will implement mandatory trainings focusing on 2 CFR Part 200, to ensure fiscal and project managers involved with grant projects are fully educated on uniform administrative requirements, including proper reporting and close-out procedures, cost principles, and audit requirements related to federal and pass-through awards. Name(s) of the contact person(s) responsible for corrective action: Terri Saltzman, Grants and Community Investment Manager. Planned completion date for corrective action plan: September 30, 2025. If the Department of Homeland Security has questions regarding this plan, please call Terri Saltzman at 863-519-2049.

Prior Finding References

2023-002

About Reporting →

FY 2023-09-30

FAC accepted this audit on April 29, 2024 — management decision was due October 29, 2024.

2023-001
Reporting
REPEAT

Certain reports reviewed had errors in the reporting as noted below: Exeption Type - Number of Items Testes - Number of Exceptions Expenditure amount did not agree to schedule of expenditures - 32 - 7 Expenditures were incorrectly classified - 32 - 7 Obligated amounts per Organization’s contract did not agree with value reported as obligated on quarterly reports - 32 - 20 Questioned costs: N/A Context: The auditors selected and tested a statistically valid sample of 8 organizations reported on the interim report and all 4 quarterly reports until a total sample of 32 items were tested. Cause: The information reported to the Treasury was not supported by accurate information. In addition, the reporting errors were not identified in the review of the reports. Effect: Inaccurate data is reported to the Treasury. Repeat Finding: Yes. Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Views of responsible officials: There is no disagreement with the audit finding.

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2023-001 Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021 through December 31, 2026 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The U.S. Treasury Department's current version of its Coronavirus State and Local Fiscal Recovery Funds Guidance on Recipient Compliance and Reporting Responsibilities (collectively, the "SLFRF Guidance") provides information on the reporting requirements of the program. During the audit period, quarterly Project and Expenditure Reports were required under this guidance. The quarterly Project and Expenditure Reports contain key line items under the following three subcategories: 1) Obligations and Expenditures, 2) Subawards, and 3) Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. Condition: Certain reports reviewed had errors in the reporting as noted below: Exeption Type - Number of Items Testes - Number of Exceptions Expenditure amount did not agree to schedule of expenditures - 32 - 7 Expenditures were incorrectly classified - 32 - 7 Obligated amounts per Organization’s contract did not agree with value reported as obligated on quarterly reports - 32 - 20 Questioned costs: N/A Context: The auditors selected and tested a statistically valid sample of 8 organizations reported on the interim report and all 4 quarterly reports until a total sample of 32 items were tested. Cause: The information reported to the Treasury was not supported by accurate information. In addition, the reporting errors were not identified in the review of the reports. Effect: Inaccurate data is reported to the Treasury. Repeat Finding: Yes. Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

2023-001-Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings noted on the FY 22/23 audit regarding expenditures and obligations were in direct correlation with the findings noted on the FY 21/22 audit. At the close of the FY 21/22 audit, quarter one and quarter two reports had been filed with Treasury. Leading into quarter three, corrections to reporting obligations were being addressed and corrected. As of the fourth quarter reporting cycle, all expenses and obligation issues were corrected. Name(s) of the contact person(s) responsible for corrective action: Christia Johnson, Budget and Management Services Director Planned completion date for corrective action plan: As mentioned above, this has already been addressed as part of the FY 21/22 audit that was finalized in April 2023, 7 months into FY 2022/23. The Budget Office will continue to follow the procedures that were put into place more than halfway through FY 22/23.

Prior Finding References

2022-005

About Reporting →
2023-002
Reporting

Certain reports reviewed had errors in the reporting as noted below: Exceptions Noted - Number of Items Tested - Number of Exceptions - Error Rate Untimely submission of quarterly reports - 19 - 11 - 58% Quarterly report submitted with incorrect grant number - 19 - 2 - 11% Missing quarterly report - 19 - 1 - 5% Porject expenditures were incorrectly stated, and no adequate documentation was provided - 19 - 15 - 79% No review performed over the quarterly reports before it is submitted to Florida Division of Emergency Management - 19 - 19 - 100% Questioned costs: N/A Context: The auditors tested 5 reports and all four quarterly reports (if applicable) with a total sample of nineteen (19) items tested. Cause: An adequate review was not being performed over the quarterly reports. Effect: Inaccurate reporting can cause the grantee to make inaccurate conclusions regarding the County’s grant programs. Repeat Finding: No Recommendation: We recommend that the quarterly reports be reviewed by an appropriate member of management. That review should be documented to ensure a complete audit trail. In addition, all reports should be stored in a centralized location for easy future access. Views of responsible officials: There is no disagreement with the audit finding.

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2023-002 Reporting Federal Agency: Department of Homeland Security Federal Program Name: Hazard Mitigation Grant Assistance Listing Number: 97.039 Federal Award Identification Number: See table below Award Period: See table below Contract Number - Contract Start Date - Contract End Date - Modificaion End Date #1 - Modification End Date #2 H0684 - 06/29/2022 - 05/31/2024 - N/A - N/A H0890 - 01/20/2023 - 09/30/2023 - 12/31/2023 - N/A H0892 - 01/20/2023 - 09/30/2023 - 12/31/2023 - N/A H0891 - 01/24/2023 - 09/30/2023 - 13/31/2023 - NA H0164 - 06/08/2019 - 03/31/-2021 - 01/31/2023 - 04/30/2024 H0165 - 02/22/2019 - 07/31/2021 - 10/31/2023 - N/A H0387 - 05/13/2020 - 01/31/2021 - 08/31/2022 - 04/30/2024 H0245 - 01/14/2020 - 08/31/2021 - 10/31/2023 - N/A H0341 - 10/06/2020 - 01/31/2022 - 13/31/2023 - N/A H0343 - 07/07/2020 - 06/30/2021 - 03/31/2024 - N/A H0349 - 11/17/2020 - 12/31/2022 - 04/30/2024 - N/A H0510 - 10/28/2021 - 04/30/2023 - 05/31/2024 - N/A H0373 - 04/20/2020 - 02/28/2022 - 10/31/2023 - N/A H0370 - 02/19/2020 - 13/31/2021 - 10/31/2023 - N/A H0488 - 01/08/2021 - 11/30/2022 - 02/09/2024 - N/A Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Consistent with 2 C.F.R. §200.328, the County shall provide the grantee with quarterly reports and a close-out report. These reports shall include the current status and progress by the County and all subcontractors in completing the work described in the County’s scope of work. Quarterly reports are due to the grantee no later than fifteen (15) days after the end of each quarter of the program year and shall be sent each quarter until submission of the administrative close-out report. The ending dates for each quarter of the program year are March 31, June 30, September 30, and December 31. Condition: Certain reports reviewed had errors in the reporting as noted below: Exceptions Noted - Number of Items Tested - Number of Exceptions - Error Rate Untimely submission of quarterly reports - 19 - 11 - 58% Quarterly report submitted with incorrect grant number - 19 - 2 - 11% Missing quarterly report - 19 - 1 - 5% Porject expenditures were incorrectly stated, and no adequate documentation was provided - 19 - 15 - 79% No review performed over the quarterly reports before it is submitted to Florida Division of Emergency Management - 19 - 19 - 100% Questioned costs: N/A Context: The auditors tested 5 reports and all four quarterly reports (if applicable) with a total sample of nineteen (19) items tested. Cause: An adequate review was not being performed over the quarterly reports. Effect: Inaccurate reporting can cause the grantee to make inaccurate conclusions regarding the County’s grant programs. Repeat Finding: No Recommendation: We recommend that the quarterly reports be reviewed by an appropriate member of management. That review should be documented to ensure a complete audit trail. In addition, all reports should be stored in a centralized location for easy future access. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Federal Agency: Department of Homeland Security Federal Program Name: Hazard Mitigation Grant Assistance Listing Number: 97.039 Recommendation: We recommend that the quarterly reports be reviewed by an appropriate member of management. That review should be documented to ensure a complete audit trail. In addition, all reports should be stored in a centralized location for easy future access. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County is working on implementing a review by management for all HMGP Grant quarterly reports. In addition, this review will be documented and stored in a centralized location for easy future access. The County is looking into creating a policy that would require divisions to save their grant information on a shared drive, while we are also looking at purchasing a grant management software as a repository for all related grant documents. Name(s) of the contact person(s) responsible for corrective action: These HMGP grants are in several divisions, so the directors over those divisions should be responsible for the corrective actions. This would include Tamara Richardson, Utilities Director; Gaye Sharpe, Parks and Natural Resources Director; Jay Jarvis, Roads and Drainage Director; and Keith Tate, Facilities Management Director. Planned completion date for corrective action plan: September 30, 2024

About Reporting →

FY 2022-09-30

FAC accepted this audit on May 31, 2023 — management decision was due December 1, 2023.

2022-003
Reporting
REPEAT

There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.

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2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? 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). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Housing and Urban Development 2022-003 Community Development Block Grant Cluster - Assistance Listing No. 14.218 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County has implemented training and procedures to make certain the reporting requirements of the Federal Funding Accountability and Transparency Act (FFATA) are properly understood by all grant staff and supervisors who perfom inputs, review, and approval, in order to ensure completeness and accuracy. Name(s) of the contact person(s) responsible for corrective action: Marcia Andresen, Health and Human Services Director Planned completion date for corrective action plan: Fully implemented prior to issuance of report.

Prior Finding References

2021-002

About Reporting →
2022-004
Reporting

2022 ? 004-Controls Over Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Emergency Rental Assistance Assistance Listing Number: 21.023 Federal Award Identification Number: 1505-0266 and 1505-0270 Award Period: September 30, 2021-September 30, 2022, for ERA1 and May 10, 2021 through September 30, 2025 for ERA 2 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: As a condition of receiving federal awards, non-federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal control to provide reasonable assurance of compliance within these requirements. The County management is responsible for establishing and maintaining internal controls over grants. Condition/Context: Auditor selected and tested a statistically valid sample of 5 financial reports and 8 performance reports from the audit period. There was no evidence of review performed on any of the 13 reports. Questioned costs: N/A Cause: During the audit period there was turnover in grant management. Reports that were previously prepared by a knowledgeable member and then reviewed by the HND Manager discontinued to be reviewed after the departure of the HND Manager. There was no assigned replacement for the review process since the original preparer ultimately was promoted into the HND Manager roll. Effect: A lack of review can cause errors to go undetected in the reporting to the grantor. Repeat Finding: No Recommendation: We recommend the County review Government Finance Officers Association's (GFOA) Best Practices for Internal Control for Grants published September 1, 2022, and update internal processes to ensure tasks and review of tasks continue even during periods of staff turnover or vacancies. The County should consider cross-training personnel to allow preparation of certain reports to be prepared and reviewed by separate knowledgeable individuals. Views of responsible officials: There is no disagreement with the audit finding.

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2022 ? 004-Controls Over Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Emergency Rental Assistance Assistance Listing Number: 21.023 Federal Award Identification Number: 1505-0266 and 1505-0270 Award Period: September 30, 2021-September 30, 2022, for ERA1 and May 10, 2021 through September 30, 2025 for ERA 2 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: As a condition of receiving federal awards, non-federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal control to provide reasonable assurance of compliance within these requirements. The County management is responsible for establishing and maintaining internal controls over grants. Condition/Context: Auditor selected and tested a statistically valid sample of 5 financial reports and 8 performance reports from the audit period. There was no evidence of review performed on any of the 13 reports. Questioned costs: N/A Cause: During the audit period there was turnover in grant management. Reports that were previously prepared by a knowledgeable member and then reviewed by the HND Manager discontinued to be reviewed after the departure of the HND Manager. There was no assigned replacement for the review process since the original preparer ultimately was promoted into the HND Manager roll. Effect: A lack of review can cause errors to go undetected in the reporting to the grantor. Repeat Finding: No Recommendation: We recommend the County review Government Finance Officers Association's (GFOA) Best Practices for Internal Control for Grants published September 1, 2022, and update internal processes to ensure tasks and review of tasks continue even during periods of staff turnover or vacancies. The County should consider cross-training personnel to allow preparation of certain reports to be prepared and reviewed by separate knowledgeable individuals. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of the Treasury 2022-004 Covid-19 Emergency Rental Assistance-Assistance Listing No. 21.023 Recommendation: We recommend the County review Government Finance Officers Association's (GFOA) Best Practices for Internal Control for Grants published September 1, 2022, and update internal processes to ensure tasks and review of tasks continue even during periods of staff turnover or vacancies. The County should consider cross-training personnel to allow preparation of certain reports to be prepared and reviewed by separate knowledgeable individuals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County has implemented training and procedures to ensure that all financial and performance reports are properly prepared by a knowledgeable staff member and then reviewed by a manager. Name(s) of the contact person(s) responsible for corrective action: Marcia Andresen Planned completion date for corrective action plan: Fully implemented prior to issuance of report.

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2022-005
Reporting

The quarterly Project and Expenditure Reports contain key line items under the following three subcategories: 1) Obligations and Expenditures, 2) Subawards, and 3) Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. Questioned costs: N/A Context: The auditors selected and tested a statistically valid sample of 10 organizations reported on the interim report and all 4 quarterly reports until a total sample of 40 items were tested. See the chart below for identified exceptions. Exception Type Number of Items Tested Number of Exceptions Missing key line-item data excluded from quarterly report 8 8 Entity type (subrecipient, beneficiary, contractor) reported was not accurate 40 23 Expenditure amount did not agree to schedule of expenditures 40 6 Obligated amounts per Organization?s contract did not agree with value reported as obligated on quarterly reports 40 40 Obligated amount was not reported in a timely manner 40 2 Cause: The key personnel assigned to reporting did not fully understand the distinction between subrecipients, contractors, and beneficiaries. Additionally, the nuances of the reporting portal caused errors for reporting obligations verse expenditures and therefore obligations reported had errors. Effect: Inaccurate data reported to the Treasury could impact the allowed funding the County can earn for these funds. Repeat Finding: No. Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Additionally, we recommend careful consideration of assignment for type of entity for which the County enters transactions with related to this funding. Views of responsible officials: There is no disagreement with the audit finding.

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2022-005-Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021 through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The U.S. Treasury Department's current version of its Coronavirus State and Local Fiscal Recovery Funds Guidance on Recipient Compliance and Reporting Responsibilities (collectively, the "SLFRF Guidance") provides information on the reporting requirements of the program. During the audit period, the Interim Report and quarterly Project and Expenditure Reports were required under this guidance. Condition: The quarterly Project and Expenditure Reports contain key line items under the following three subcategories: 1) Obligations and Expenditures, 2) Subawards, and 3) Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. Questioned costs: N/A Context: The auditors selected and tested a statistically valid sample of 10 organizations reported on the interim report and all 4 quarterly reports until a total sample of 40 items were tested. See the chart below for identified exceptions. Exception Type Number of Items Tested Number of Exceptions Missing key line-item data excluded from quarterly report 8 8 Entity type (subrecipient, beneficiary, contractor) reported was not accurate 40 23 Expenditure amount did not agree to schedule of expenditures 40 6 Obligated amounts per Organization?s contract did not agree with value reported as obligated on quarterly reports 40 40 Obligated amount was not reported in a timely manner 40 2 Cause: The key personnel assigned to reporting did not fully understand the distinction between subrecipients, contractors, and beneficiaries. Additionally, the nuances of the reporting portal caused errors for reporting obligations verse expenditures and therefore obligations reported had errors. Effect: Inaccurate data reported to the Treasury could impact the allowed funding the County can earn for these funds. Repeat Finding: No. Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Additionally, we recommend careful consideration of assignment for type of entity for which the County enters transactions with related to this funding. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of the Treasury 2022-005 Covid-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Additionally, we recommend careful consideration of assignment for type of entity for which the County enters transactions with related to this funding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The COVID-19 funds were distributed under an emergency declaration due to the worldwide pandemic and had to be administered by staff with limited grant experience. The County is implementing processes and procedures regarding the reconciliation of transactions to ensure accurate reporting of expenditures for each quarter and to make any necessary corrections in subsequent quarterly reports. Processes and procedures are also being implemented to properly identify subrecipients, contractors, and beneficiaries. Staff will review the most recent Federal guidance, training, and webinars as necessary to ensure they are up to date with the most recent information. Name(s) of the contact person(s) responsible for corrective action: Christia Johnson, Budget and Management Services Director Planned completion date for corrective action plan: June 30, 2023

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2022-006
Other

The revenue loss calculation was not calculated in accordance with the guidance provided by the Treasury?s Final Rule. Questioned costs: N/A Context: The original revenue loss calculation allowed for loss revenue provisions of approximately $31 million. The corrected and revised calculation was approximately $29 million. Cause: The key roles assigned to doing this calculation experienced turnover. In addition, certain accounts were included in the calculation that should not have been included resulting in a lower loss revenue amount. Effect: The original calculation resulted a Coronavirus State and Local Fiscal Recovery Funds budget that included an amount for revenue loss that was higher than what is allowable by the Treasury?s Final Rule. Repeat Finding: No. Recommendation: We recommend the County designate a reviewer to perform a detailed review of future revenue loss calculations to ensure the calculation complies with the requirements of the Treasury?s Final Rule. Views of responsible officials: There is no disagreement with the audit finding.

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2022-006-Revenue Loss Calculation Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021 through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Coronavirus State and Local Fiscal Recovery Funds (CSLFR) provide needed fiscal relief for recipients that have experienced revenue loss due to the onset of the COVID-19 public health emergency. Specifically, SLFRF funding may be used to pay for ?government services? in an amount equal to the revenue loss experienced by the recipient due to the COVID-19 public health emergency. Government services generally include any service traditionally provided by a government, including construction of roads and other infrastructure, provision of public safety and other services, and health and educational services. Funds spent under government services are subject to streamlined reporting and compliance requirements. In order to use funds under government services, recipients should first determine revenue loss. The Treasury's final rule provides the guidance for how revenue loss is calculated. Condition: The revenue loss calculation was not calculated in accordance with the guidance provided by the Treasury?s Final Rule. Questioned costs: N/A Context: The original revenue loss calculation allowed for loss revenue provisions of approximately $31 million. The corrected and revised calculation was approximately $29 million. Cause: The key roles assigned to doing this calculation experienced turnover. In addition, certain accounts were included in the calculation that should not have been included resulting in a lower loss revenue amount. Effect: The original calculation resulted a Coronavirus State and Local Fiscal Recovery Funds budget that included an amount for revenue loss that was higher than what is allowable by the Treasury?s Final Rule. Repeat Finding: No. Recommendation: We recommend the County designate a reviewer to perform a detailed review of future revenue loss calculations to ensure the calculation complies with the requirements of the Treasury?s Final Rule. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of the Treasury 2022-006 Covid-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend the County designate a reviewer to perform a detailed review of future revenue loss calculations to ensure the calculation complies with the requirements of the Treasury's Final Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The rules regarding the Lost Revenue Calculation were complex and difficult to understand. The County is implementing training and procedures, including review by knowledgeable staff, to ensure the Lost Revenue Calculation complies with the Treasury's Final Rule. Name(s) of the contact person(s) responsible for corrective action: Christia Johnson Planned completion date for corrective action plan: September 30, 2023

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2022-007
Subrecipient Monitoring

During the testing of quarterly Project and Expenditure Reports submitted to the Treasury, information included for contracts and subawards was not agreeing to information reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors selected reported subrecipients, beneficiaries, and contractors to determine the validity of assigned category. A subrecipient is an entity that receives a subaward to carry out a project funded by Fiscal Recovery Funds on behalf of a recipient. Individuals or entities that are direct beneficiaries of a project funded by Fiscal Recovery Funds are not considered subrecipients. Households, communities, small businesses, nonprofits, and impacted industries are all potential beneficiaries of projects carried out with SLFRF funds. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. Beneficiaries are not subject to the requirements placed on subrecipients in the Uniform Guidance. The distinction between a subrecipient and a beneficiary, therefore, is contingent upon the rationale for why a recipient is providing funds to the individual or entity. If the recipient is providing funds to the individual or entity for the purpose of carrying out a SLFRF program or project on behalf of the recipient, the individual or entity is acting as a subrecipient. Acting as a subrecipient, the individual or entity is subject to subrecipient monitoring and reporting requirements. Questioned costs: N/A Context: A statistically valid sample of 10 organizations listed on each of the quarterly Treasury reports (40 total items tested) was selected and tested against the entity-type determination criteria. In the sample of 40 entity types reported, there were twenty-three exceptions (23) which resulted in a conclusion that only one (1) Organization reported was truly a subrecipient. This subrecipient was not captured on the SEFA and the elements of monitoring were not in place. The review of the contract agreement between Polk County and this subrecipient did not meet all requirements under 2 CFR section 200.332(a). Cause: The distinction between the entity types receiving this federal funding was not fully understood by personnel. Effect: Recipients and subrecipients are the first line of defense and responsible for ensuring the SLFRF award funds are not used for ineligible purposes, and there is no fraud, waste, or abuse associated with their SLFRF award. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. A lack of monitoring can lead to noncompliance by the subrecipient which ultimately impacts the compliance of the pass-through entity. Repeat Finding: No. Recommendation: We recommend an amended subrecipient contract that complies with all guidelines under 2 CFR section 200.332(a) be put into place between Polk County and the identified subrecipient. In addition, we recommend a risk assessment of this subrecipient be performed and depending on the results of the assessment, determine a planned schedule of monitoring that matches frequency and intensity that aligns with the risk assessment. Views of responsible officials: There is no disagreement with the audit finding.

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2022-007-Subrecipient Monitoring Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021, through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR section 200.332(a) notes pass-through entities such as Polk County, Florida need to ensure that every subaward is clearly identified to the subrecipient as a subaward and includes required information at the time of the subaward sufficient for the subrecipient to comply with federal statutes, regulation, and the terms and conditions of the award. If any of the data elements change the impact should be updated in subsequent subaward modification. 2 CFR section 200.332(b)-(f) covers required monitoring activities and management of subrecipient relationships that should be performed by the pass-through entity. Condition: During the testing of quarterly Project and Expenditure Reports submitted to the Treasury, information included for contracts and subawards was not agreeing to information reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors selected reported subrecipients, beneficiaries, and contractors to determine the validity of assigned category. A subrecipient is an entity that receives a subaward to carry out a project funded by Fiscal Recovery Funds on behalf of a recipient. Individuals or entities that are direct beneficiaries of a project funded by Fiscal Recovery Funds are not considered subrecipients. Households, communities, small businesses, nonprofits, and impacted industries are all potential beneficiaries of projects carried out with SLFRF funds. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. Beneficiaries are not subject to the requirements placed on subrecipients in the Uniform Guidance. The distinction between a subrecipient and a beneficiary, therefore, is contingent upon the rationale for why a recipient is providing funds to the individual or entity. If the recipient is providing funds to the individual or entity for the purpose of carrying out a SLFRF program or project on behalf of the recipient, the individual or entity is acting as a subrecipient. Acting as a subrecipient, the individual or entity is subject to subrecipient monitoring and reporting requirements. Questioned costs: N/A Context: A statistically valid sample of 10 organizations listed on each of the quarterly Treasury reports (40 total items tested) was selected and tested against the entity-type determination criteria. In the sample of 40 entity types reported, there were twenty-three exceptions (23) which resulted in a conclusion that only one (1) Organization reported was truly a subrecipient. This subrecipient was not captured on the SEFA and the elements of monitoring were not in place. The review of the contract agreement between Polk County and this subrecipient did not meet all requirements under 2 CFR section 200.332(a). Cause: The distinction between the entity types receiving this federal funding was not fully understood by personnel. Effect: Recipients and subrecipients are the first line of defense and responsible for ensuring the SLFRF award funds are not used for ineligible purposes, and there is no fraud, waste, or abuse associated with their SLFRF award. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. A lack of monitoring can lead to noncompliance by the subrecipient which ultimately impacts the compliance of the pass-through entity. Repeat Finding: No. Recommendation: We recommend an amended subrecipient contract that complies with all guidelines under 2 CFR section 200.332(a) be put into place between Polk County and the identified subrecipient. In addition, we recommend a risk assessment of this subrecipient be performed and depending on the results of the assessment, determine a planned schedule of monitoring that matches frequency and intensity that aligns with the risk assessment. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of the Treasury 2022-007 Covid-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend an amended subrecipient contract that complies with all guidelines under 2 CFR section 200.332(a) be put into place between Polk County and the identified subrecipient. In addition, we recommend a risk assessment of this subrecipient be performed and depending on the results of the assessment, determine a planned schedule of monitoring that matches frequency and intensity that aligns with the risk assessment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County is implementing training and procedures to properly identify and classify subrecipients on the Schedule of Expenditures of Federal Awards and State Financial Assistance, and to ensure that all required subrecipient monitoring is properly performed. Additionally, the contract for a subrecipient identified during the audit is being amended to comply with all applicable requirements. Name(s) of the contact person(s) responsible for corrective action: Christia Johnson Planned completion date for corrective action plan: June 15, 2023. Approval of amended contract expected in August 2023.

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FY 2021-09-30

FAC accepted this audit on June 22, 2022 — management decision was due December 22, 2022.

2021-002
Reporting

There are 33 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. As no FFATA reporting had been done during the audit period, our selection of 8 transactions resulted in 8 exceptions. Questioned costs: None Context: In a statistically valid sample of 8 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 8 8 8 8 8 Dollar Value $427,977 $427,977 $427,977 $427,977 $427,977 Cause: Management was unaware of the FFATA reporting requirements under this grant. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision-makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: No Recommendation: We recommend the County review all subaward agreements and identify any agreements with a value of $30,000 or greater and then ensure the proper reporting is performed in FSRS. Views of responsible officials: There is no disagreement with the audit finding.

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2021 ? 002-Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Assistance Listing Number: 14.218 Award Period: October 2020 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? 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). Condition: There are 33 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. As no FFATA reporting had been done during the audit period, our selection of 8 transactions resulted in 8 exceptions. Questioned costs: None Context: In a statistically valid sample of 8 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 8 8 8 8 8 Dollar Value $427,977 $427,977 $427,977 $427,977 $427,977 Cause: Management was unaware of the FFATA reporting requirements under this grant. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision-makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: No Recommendation: We recommend the County review all subaward agreements and identify any agreements with a value of $30,000 or greater and then ensure the proper reporting is performed in FSRS. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

CORRECTIVE ACTION PLAN Polk County, Florida respectfully submits the following corrective action plan for the year ended September 30, 2021. Audit period: October 1, 2020 ? September 30, 2021 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS 2021-001 Material Audit Adjustments Recommendation: We recommend the County implement additional year-end close internal controls. These controls should include reconciling every account and ensure each reconciliation is reviewed for accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Accounting Manager position has been filled with a Certified Public Accountant. Additional training has been provided to staff and will continue to be provided to accounting staff across the County. The process for accepting escrow deposits will be modified so that revenue is deposited timelier and the escrow account will be properly reconciled. Name(s) of the contact person(s) responsible for corrective action: Dee Dee Beaver, CPA, CGFO Comptroller Division Director Planned completion date for corrective action plan: Accounting Manager position has been filled, additional training has been provided to comptroller division staff, the escrow account is currently being reconciled monthly. The remaining items will be completed by 8/30/2022. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S Department of Housing and Urban Development 2021-002 Reporting Community Development Block Grant ? Assistance Listing No. 14.218 Recommendation: We recommend the County review all subaward agreements and identify any agreements with a value of $30,000 or greater and then ensure the proper reporting is performed in the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County has brought the required reporting current. Name(s) of the contact person(s) responsible for corrective action: Nancy Hurley, Housing Compliance Program Manager Planned completion date for corrective action plan: The County has completed the reporting for Fiscal year 2020-2021 and currently in fiscal year 2021-2022.

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FY 2020-09-30

FAC accepted this audit on April 29, 2021 — management decision was due October 29, 2021.

2020-001
Activities Allowed or Unallowed / Cost Allowability
QUESTIONED COSTS

One disbursement for the Coronavirus Relief Fund funding was made more than the approved amount. The applicant?s application was approved for $2,000 of assistance but the check issued to the applicant was for $2,500. Questioned costs: $500 Context: In a statistically valid sample of 60 disbursements tested the auditors noted that one disbursement was made which did not match the approved value of the disbursement which caused an overpayment of $500 to an applicant who received economics assistance related to COVID-19. The total expenditures related to the Coronavirus relief fund was $85,690,841. Our sample selected for testing totaled $8,708,530. The error rate noted in the sample tested was 0.006%. Cause: These grant funds were being distributed under an emergency declaration due to the COVID-19 worldwide pandemic and extraordinary measures were being taken to get the money to those Polk County citizens in need. Originally when the Polk Care Business Relief program was established, a company with 2 or more employees was to be paid at $2,500. Subsequently a policy change was made to increase this amount to $5,000. Sole proprietors were originally $1,000 and increased to $2,000. This applicant was originally paid $2,500 based upon policy and application information available at that time. Subsequently, upon review of a second applicant and information provided that related to the first applicant, staff was able to determine that the first applicant was misclassified and should have received a lesser amount as a sole proprietor. At the same time initial applicants were being processed to be paid the net amount resulting from a policy change to increase the amount of assistance. Due to the unusually high volume of transactions being processed expeditiously staff ensured that the second check did not get processed but failed to request the resulting $500 overpayment from the original applicant. In summary, staff originally determined the issue and a refund has been requested from the applicant for the overpayment. Effect: Payments made which do not match the approved totals of the program can cause over or under payments to be made for COVID-19 related relief. Repeat Finding: No Recommendation: We recommend the County implement additional review procedures between the application and approved payment requests. Views of responsible officials: There is no disagreement with the audit finding.

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Criteria or specific requirement: Per the Treasury Guidance published in the Federal Register on January 15, 2021, necessary expenditures incurred due to the public health emergency included providing economic support to those suffering from employment or business interruptions due to COVID-19-related business closures. The maximum value paid to a sole proprietor should be $2,000. Condition: One disbursement for the Coronavirus Relief Fund funding was made more than the approved amount. The applicant?s application was approved for $2,000 of assistance but the check issued to the applicant was for $2,500. Questioned costs: $500 Context: In a statistically valid sample of 60 disbursements tested the auditors noted that one disbursement was made which did not match the approved value of the disbursement which caused an overpayment of $500 to an applicant who received economics assistance related to COVID-19. The total expenditures related to the Coronavirus relief fund was $85,690,841. Our sample selected for testing totaled $8,708,530. The error rate noted in the sample tested was 0.006%. Cause: These grant funds were being distributed under an emergency declaration due to the COVID-19 worldwide pandemic and extraordinary measures were being taken to get the money to those Polk County citizens in need. Originally when the Polk Care Business Relief program was established, a company with 2 or more employees was to be paid at $2,500. Subsequently a policy change was made to increase this amount to $5,000. Sole proprietors were originally $1,000 and increased to $2,000. This applicant was originally paid $2,500 based upon policy and application information available at that time. Subsequently, upon review of a second applicant and information provided that related to the first applicant, staff was able to determine that the first applicant was misclassified and should have received a lesser amount as a sole proprietor. At the same time initial applicants were being processed to be paid the net amount resulting from a policy change to increase the amount of assistance. Due to the unusually high volume of transactions being processed expeditiously staff ensured that the second check did not get processed but failed to request the resulting $500 overpayment from the original applicant. In summary, staff originally determined the issue and a refund has been requested from the applicant for the overpayment. Effect: Payments made which do not match the approved totals of the program can cause over or under payments to be made for COVID-19 related relief. Repeat Finding: No Recommendation: We recommend the County implement additional review procedures between the application and approved payment requests. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

CORRECTIVE ACTION PLAN Polk County Florida respectfully submits the following corrective action plan for the year ended September 30, 2020. Audit period October 1, 2019 ? September 30, 2020 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule FINDINGS-MAJOR FEDERAL PROGRAM AND STATE PROJECTS SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS 2020-001 Allowable Costs and Activities Recommendation: We recommend the County implement additional review procedures to ensure the accurate amount is paid. Explanation of disagreement with the audit finding: There is no disagreement with the audit finding. Action taken in response to finding: These grant funds were being distributed under an emergency declaration due to the COVID-19 worldwide pandemic and extraordinary measures were being taken to get the money to those Polk County citizens in need. Originally when the Polk Care Business Relief program was established, a company with 2 or more employees was to be paid at $2,500. Subsequently a policy change was made to increase this amount to $5,000. Sole proprietors were originally $1,000 and increased to $2,000. This applicant was originally paid $2,500 based upon policy and application information available at that time. Subsequently, upon review of a second applicant and information provided that related to the first applicant, staff was able to determine that the first applicant was misclassified and should have received a lesser amount as a sole proprietor. At the same time initial applicants were being processed to be paid the net amount resulting from a policy change to increase the amount of assistance. Due to the unusually high volume of transactions being processed expeditiously staff ensured that the second check did not get processed but failed to request the resulting $500 overpayment from the original applicant. In summary, staff originally determined the issue and a refund was requested and subsequently received from the applicant in the amount of $500 on March 26, 2021. Name of contact person(s) responsible for corrective action: Todd J. Bond Deputy County Manager 863-534-6031 Planned completion date for corrective action plan: Refund requested from applicant on March 22, 2021. Refund in the amount of $500 was received on March 26, 2021. William D. Beasley County Manager

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