City of AuroraLocal Government

Finding: Allowable Costs Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Sponsoring Agency: Department of Treasury Sponsoring Award Number: None provided Award Year: 2021 "Criteria: Per the Coronavirus State and Local Fiscal Recovery Fund (SLFRF) Final Rule and Frequently Asked Questions, recipients may use SLFRF funds for various reasons including respoinding to the Public Health Emergency and negative economic impacts from the pandemic, which includes bolstering the public sector capacity and workforce such as payroll and covered benefits for employees of a recipient government for the portion of the employee's time spent responding to COVID-19. " Condition: The City of Aurora (the City) charged payroll and benefits for one employee subsequent to time in which the employee no longer was working on COVID-19 related projects for the City. Questioned Costs: $22,602 Context: The City charged three employees payroll and benefits to the SLFRF program for at total of $299,169. We compared 100% of the payroll to underlying employee contracts and cost allocation reports and noted one employee's payroll and benefits should have been charged to the SLFRF program from January to September 9, 2023, however all payroll through December 2023 was charged to the program. Effect: Unallowable costs were charged to the SLFRF program. Failure to ensure compliance with federal requirements for the SLFRF program program requirements could result in disallowed costs and federal sanctions, including the termination of the federal program. Cause: The City did not have proper internal controls in place to identify and communicate the change in employees job duties. In addition, the City's time and effort certifications happen on an annual basis which does not provide adqueate time to correct changes in employees job functions/allocations of cost. Identification as a repeat finding: Not Applicable Recommendation: We recommend City staff implement internal controls to identify changes in employee job duties and allocations of costs. In addition, we recommend the City increase the frequency of time and effort certifications in order to identify changes on a more timely basis. Views of Responsible Officials and Planned Corrective Actions: The City agrees with the finding. See separate report for planned corrective actions.

Finding: Reporting Program: Emergency Rental Assistance Program Assistance Listing Number: 21.023 Sponsoring Agency: Department of Treasury Sponsor Award Number: ERA1 1505-0266 and ERA2 1505-0270 Criteria: The Emergency Rental Assistance (ERA) Program Reporting Guide requires that all ERA1 and ERA2 Recipients gather and track required information throughout each reporting period and submit required reports using Treasury?s online reporting portal.The ERA program requires ERA Recipients to certify and submit quarterly reports. The reporting guide further outlines the submission deadline for each required quarterly report. Condition: The City of Aurora was unable to submit the quarterly reports due in October 2021. Questioned Costs: None Context: Three Quarterly Reports under the ERA1 grant award and two Quarterly Reports under the ERA 2 grant award were required to be submitted by October 29, 2021. None of the quarterly ports due in October 2021 have been submitted by the City. Effect: The City has not complied with reporting requirements associated with the ERA1 and ERA2 grant awards and therefore the Department of Treasury may not have all the information associated with the activity of the program they need to monitor the program. Cause: The City has attempted to file the reports; however, issues within the Department of Treasury portal have prevented the City from being able to finalize the reports due in October 2021. The City has submitted and has several open tickets for assistance from the Department of Treasury; however, the issue has not been resolved. Identification as a repeat finding: Not applicable. Recommendation: We recommend the City continue to work with the Department of Treasury to attempt to resolve the issues preventing the submission of the reports and submit the past-due reports as soon as possible. Views of Responsible Officials: The City agrees with the finding. See separate report for planned corrective actions.

Finding: Eligibility Program: Emergency Rental Assistance Program Assistance Listing Number: 21.023 Sponsoring Agency: Department of Treasury Sponsor Award Number: ERA1 1505-0266 Criteria: The Emergency Rental Assistance (ERA) funds may be used for rent and rental arrears. The Treasury ERA Frequently Asked Questions (FAQs) dated August of 2021 outline the requirements grantees are to follow in making eligibility determinations and how those determinations should be documented. Question 5 of the FAQs addresses how a grantee should document where an applicant resides and the amount of rent or rental arrears owed. It specifically states "Grantees must obtain, if available, a current lease, signed by the applicant and the landlord or sublessor, that identifies the unit where the applicant resides and establishes the rental payment amount. If a household does not have a signed lease, documentation of residence may include evidence of paying utilities for the residential unit, an attestation by a landlord who can be identified as the verified owner or management agent of the unit, or other reasonable documentation as determined by the grantee. In the absence of a signed lease, evidence of the amount of a rental payment may include bank statements, check stubs, or other documentation that reasonably establishes a pattern of paying rent, a written attestation by a landlord who can be verified as the legitimate owner or management agent of the unit, or other reasonable documentation as defined by the grantee in its policies and procedures." Condition: The City of Aurora did not have formal documentation supporting the residence was verified prior to making a rental assistance payment to one recipient whose application was supported by an expired lease. Questioned Costs: $2,550 Context: The City of Aurora paid rental assistance of $3,129,167 to 618 recipients. We selected a sample of 25 recipients for testing and noted the above condition. A non-statistical sampling methodology was used to select the samples. Effect: The recipient may not have qualified for the level of funding they received. Cause: The City did not formally document the steps it took to confirm the recipients documentation of residence after receiving an expired lease. Identification as a repeat finding: Not applicable. Recommendation: We recommend the City ensure formal documentation is received and retained to support all eligibility determinations. Views of Responsible Officials: The City agrees with the finding. See separate report for planned corrective actions.

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