CITY OF MIAMI

Reporting Requirements Criteria: Per the Compliance and Reporting Guidance for Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), all recipients are required to submit Project and Expenditure Reports. Annual reports are required for cities below 250,000 residents that are allocated less than $10 million in CSLFRF funding and must be submitted to the Department of Treasury by April 30. In addition, according to the City’s internal control polices, the City has established channels of communication and systems for tracking the sources of grant funding, both state and federal. Additionally, the City received a reimbursement based grant award in 2023 which management did not thoroughly determine the funding source for appropriate inclusion or exclusion from the schedule of expenditures of federal awards (SEFA). Upon the conclusion of audit test work, it was determined the grant awarded came from state sources, and thus would not be included in the SEFA. Condition: The City’s internal controls over required reporting requirements were not timely monitored and tracked. Questioned Costs: $0 Cause and Effect: Due to the City not having a centralized reporting requirement schedule, the required annual report for CSLFRF funding was not submitted by April 30, 2023, and therefore was not in compliance with the compliance reporting requirements. As of the end of audit fieldwork, this report was still pending submission to the Department of Treasury. As a result of the City’s lack of oversight for the funding source of a grant, potential non-compliance could exist as requirements for federal versus state awards may differ. This also could be overlooked for appropriate inclusion in the SEFA, resulting in improper reporting. Recommendation: We recommend the City centrally tracks its required grant reporting and related deadlines with specific individuals identified by grant for each individual’s responsibility in meeting the reporting deadlines. Management Response: With the turnover in staff and management in the department, the new Finance Director submitted for login credentials to SLFRF@treasury.gov in order to complete required reporting. The email for login credentials was sent on April 28, 2023. Once login credentials were received, the final report was submitted on November 6, 2023. To date, no penalties have been reported by the Treasury. Additionally, we are working to centrally track grants and loans moving forward and communicating this with department heads and the interim city manager.

Inadequate Records Retention (Procurement) Criteria: Per Federal regulations for general procurement standards (2 CFR § 200.318 (i)), non-Federal entity must maintain records sufficient to detail the history of the procurement process. These records will include but are not limited to, the following: Rationale for the method of procurement, selection or rejection, and the basis for the contract price. Condition: In our procurement testing for CSLFRF funding, the City was unable to provide evidence that demonstrates public notice was published according to (2 CFR § 200.320(b)) for 1 of the 5 projects selected. Questioned Costs: $0 Cause and Effect: Due to the City not having a centralized repository for procurement records, sufficient evidence was unable to verify that procurements provide full and open competition to potential bidders, as there was a lack of documentation related to the public notice for open bidding to occur. Recommendation: We recommend the City updates their procurement policies and procedures by centrally tracking procurement documents for up to five years. Centrally tracking documentation will help the City mitigate potential contractual and administrative issues related to procurement. Management Response: The Finance Director is initiating conversations with department heads regarding updating procurement policies and procedures. We are taking steps to ensure all procurement documents are stored centrally in order for these items to be readily available moving forward.