Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 17, 2024. 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 July 17, 2024, which was (763 days ago).
What is a management decision? →For the Community Development Block Grant, the City did not have adequate documentation of internal controls in place related to the program’s reporting of the Quarterly Financial Reports or the Financial Summary Report.
The management team agrees with the auditor’s recommendation and has already implemented additional controls to address the stated concerns. Effective July 1, 2023, the City Grants Department adopted a new grants management system, Monday.com. This system allows for electronic tracking and audit record or report review and approval. The Grants Director is responsible for the corrective action as it relates to this finding.
For the Community Development Block Grant Program, the City did not submit reports in a timely manner. The City did not comply with the requirement to report the information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award modification was made.
The management team agrees with the auditor’s recommendation and has already implemented additional controls to address the stated concerns. These subawards were in place through another department at the time that the newly formed Grants department was created. In the transition of responsibility between departments, the FFATA reporting was delayed. Through the new grants management system, Monday.com, the department has set-up automations to ensure that FFATA reporting is done in a timely manner and contains an electronic audit record. The Grants Director is responsible for the corrective action as it relates to this finding.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 16, 2023. 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 July 16, 2023, which was (1130 days ago).
What is a management decision? →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 maintain internal control to provide reasonable assurance of compliance with these requirements. In accordance with 24 CFR 576.203(a)(1) and (2), metropolitan cities have up to 240 days from the date HUD signs the grant agreement to obligate ESG-CV funds. Condition: Of the $1,822,554 expenditures, $1,388,295 was distributed to subrecipients and of that, $237,361 was not obligated to the subrecipient until 271 days after the date of the signed agreement. Cause: Controls over the timely obligation of federal funds were not operating as designed over a portion of the ESG-CV funds. Effect: This portion of the ESG-CV funds were not obligated in a timely manner. Questioned Costs: None. Context: During our testing it was noted that a control was in place for review of the obligation date, however, the review related to obligation of funds was not set to occur within the required timeframe. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management establish and maintain effective internal control ensuring timely review in order to comply with the obligation requirements of the program. Management Response: See Corrective Action Plan.
The management team agrees with the auditor?s recommendation and has already implemented additional controls to address the stated concerns. Effective July 1, 2022, the City created a separate Grants division to centralize the application, compliance and administration of federal grants. This department is responsible for creating a City-wide Grants Policy and Procedures Manual related to grants including but not limited to: acceptance of an award, managing an award, initiating and monitoring subawards, programmatic and financial reporting and closeout of awards. The Grants Director is responsible for the corrective action as it relates to this finding.
Criteria or Specific Requirement: In accordance with the Department of Treasury ERA1 reporting guidance, grantees are required to submit monthly reports by the 15th of the following month and quarterly reports by the 15th day of the month following the calendar quarter end. Condition: There were three monthly reports selected for testing, of which 2 were submitted late. The February 2022 monthly report was submitted two days late on March 15, 2022, and the April 2022 monthly report was submitted one day late on May 17, 2022. Note the 15th fell on a Sunday, thereby making the due date Monday, May 16, 2022. Of the two quarterly reports selected for testing, one was submitted three days late on July 18, 2022, instead of the 15th of the month as required. Cause: Controls were not consistently applied. Effect: The City did not have effective controls in place to ensure timely submission of reports by the required due date. Questioned Costs: None. Context: Guidance for required submission dates is provided for each month and each quarter so that it is clear to grantees which dates are the dues dates for both monthly and quarterly reports. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management establish and maintain effective internal control ensuring timely submission required under the Department of Treasury ERA1 reporting guidance. In addition, we recommend that the City conduct formal training to ensure that management has sufficient knowledge of the applicable reporting requirements. Management Response: See Corrective Action Plan.
The management team agrees with the auditor?s recommendation and has already implemented additional controls to address the stated concerns. Effective July 1, 2022, the City created a separate Grants division to centralize the application, compliance and administration of federal grants. This department is responsible for creating a City-wide Grants Policy and Procedures Manual related to grants including but not limited to: acceptance of an award, managing an award, initiating and monitoring subawards, programmatic and financial reporting and closeout of awards. The Grants Director is responsible for the corrective action as it relates to this finding.
Criteria or Specific Requirement: In accordance with 2 CFR section 200.332(b), each subrecipient?s risk of noncompliance must be evaluated. Condition: The City has two subrecipients under this grant receiving $674,871 out of expenditures of $1,187,264. The documentation of the risk assessment for one of the subrecipients who received $103,621 could not be found. Cause: Due care as it relates to documentation retention was not in place. Effect: The City does not have evidence that the subrecipient has low risk of noncompliance. Questioned Costs: None. Context: Other elements of subrecipient monitoring, such as the oversight of expenditures of funds via monthly and/or quarterly reporting, were in place. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management establish and maintain effective internal control ensuring proper risk assessment procedures as well as a process of ensuring document retention. Management Response: See Corrective Action Plan.
The management team agrees with the auditor?s recommendation and has already implemented additional controls to address the stated concerns. Effective July 1, 2022, the City created a separate Grants division to centralize the application, compliance and administration of federal grants. This department is responsible for creating a City-wide Grants Policy and Procedures Manual related to grants including but not limited to: acceptance of an award, managing an award, initiating and monitoring subawards, programmatic and financial reporting and closeout of awards. The Grants Director is responsible for the corrective action as it relates to this finding.
Criteria or Specific Requirement: Grant recipients must comply with Uniform Guidance for procurement, specifically with 2 CFR sections 200.318 thru 200.327 including ensuring the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 DFR section 200.320. Condition: The City did not comply with 2 CFR 200.320 or with City procurement policies. The City did not obtain quotes for a project for upgrades to the financial system for the purpose of grants accounting and management. Cause: The City began the system upgrade project in a prior year using 21.019 CARES CRF funding. Under that grant program, procurement standards were not applicable under Uniform Guidance. Those funds were set to expire December 2021. Therefore, management concluded that since those expenditures were also allowable under 21.027, they would complete the project using funds from the Coronavirus State and Local Fiscal Recover Funds grant (Assistance Listing (AL)21.027). However, under the AL 21.027 grant, the City is required to follow the Uniform Guidance for procurement of contracts. Effect: The City is out of compliance with procurement requirements. Questioned Costs: None. Context: A small purchase could have been applied as the total amount spent under the contract was more than the micro-purchase amount but less than the simplified acquisition threshold. Under small purchase procedures price or rate quotes must be obtained. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management establish and maintain effective internal control ensuring an understanding of compliance requirements prior to entering into contracts with vendors with intention of using of grant monies. Management Response: See Corrective Action Plan.
The management team agrees with the auditor?s recommendation and has already implemented controls to address the stated concerns. Due to the public health emergency related to COVID-19, management elected to use the exception under 2 CFR 200.320(c)(3) due to the public exigency or emergency. However, management understands that the related compliance requirements have since been updated and we have adopted procedures to review any updates to compliance requirements prior to executing contracts with federal awards. Additionally, the Grants division has attended multiple trainings since the occurrence pertaining to SLFRF compliance requirements. The Grants Director also subscribes to several listserv notices to keep current on any changes in guidance. The Grants Director is responsible for the corrective action as it relates to this finding.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 11, 2021. 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 11, 2021, which was (1773 days ago).
What is a management decision? →Federal program: Highway Planning and Construction (CFDA #20.205) / Drinking Water State Revolving Loan Fund (CFDA #66.468) Criteria or specific requirement: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non- Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/ (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: We were informed during the audit that the City did not maintain evidence to support that a suspension and debarment check was performed for the three vendors selected for testing for the Highway Planning and Construction grant. Additionally, we noted that the searches performed for the five vendors selected for testing related to the Drinking Water State Revolving Funds were not performed timely. The searches should be performed prior to signing the award or contract in accordance with the Purchasing Policy effective January 28, 2019. Cause: The department experienced some staffing turn-over as a result of the City implementing staff realignment throughout the City. Additionally, personnel were not aware that they had to maintain documentation to indicate performance of procedures. Effect or potential effect: The City could have entered into transactions with vendors who are suspended or debarred from receiving federal funds resulting in non-compliance with State and Federal regulations. Questioned costs: N/A Context: Support for three of three vendors selected for testing for the Highway Planning and Construction grant was not maintained and procedures performed for five of five vendors selected for testing for the Drinking Water State Revolving Funds were not performed timely Repeat finding, prior audit finding number: Yes, 2019-004 Recommendation: We recommend that training be provided to all employees involved in the procurement process to ensure that they are aware of the requirements related to purchases using federal funds. View of responsible officials and planned corrective action: Debarment check for new vendors will now be performed by the Purchasing Division to ensure compliance and facilitate record retention.
Beginning April 1, 2021, debarment checks for new vendors will be performed by the Purchasing Division to ensure compliance and facilitate record retention.
2019-004
Federal program: Community Development Block Grants/Entitlement Grants (CFDA #14.218) Criteria or specific requirement: The schedule of expenditures of federal awards (SEFA) shall be complete and accurate and agree to supporting records/documentation, in accordance with the Uniform Guidance. Condition: Per discussion with the Housing and Neighborhood Services Manager on March 18, 2021, we were informed that the Downtown Library project was cancelled subsequent to year-end. As a result of the cancellation, there were 3 invoices totaling $121,323 which were no longer billable to the grantor and therefore should not be reflected in the FY 2020 SEFA. Cause: Lack of communication between the Housing and Neighborhood Services department and Finance Departments. Effect or potential effect: The SEFA was overstated by $121,323 Questioned costs: N/A Context: We tested a sample of 50 total expenditures for this program and found 3 exceptions as noted in the condition. Repeat finding, prior audit finding number: Yes, 2019-005 Recommendation: Management should adopt, implement and monitor compliance with policies and procedures designed to provide reasonable assurance that the schedule of expenditures of federal awards is complete and accurate. Additional resources should be made available to provide training and other resources to those delegated with the primary responsibility for grant compliance and the terms of the grants should be communicated to all personnel involved in administering federal grants. We recommend that management review the general ledger detail subsequent to year end and reimbursement requests received from subrecipients subsequent to year end to ensure that grant expenditures are recorded to the proper period for SEFA reporting purposes. Views of responsible officials and planned corrective action: Additional training will be provided to all employees responsible for compliance. Also, monthly financial reviews will be conducted by finance department personnel in conjunction with the grant administrative team.
Training will be provided to all employees responsible for compliance. Additionally, beginning in January 2021, monthly financial reviews are being conducted by finance department personnel in conjunction with grant administration team.
2019-005
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 10, 2020. 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 July 10, 2020, which was (2231 days ago).
What is a management decision? →Federal program Investments for Public Works and Economic Development Facilities (CFDA #11.300) Criteria or specific requirement Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non- Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (?.36(i)(5)); OMB Circular A-110 (2 CFR part 215, Appendix A, Contract Provisions); 2 CFR part 176, subpart C; and 2 CFR section 200.326). Condition and context Per examination of six certified payrolls, we noted that one payroll for Meadows Construction for the week ended December 25, 2018, was not properly submitted and therefore did not contain the contractor's certification. Per inquiry with the Construction Financial Coordinator on October 17, 2019, the contractor approved the payroll on October 28, 2019. A statistically valid sample was used No Questioned costs N/A Effect The City is not in compliance with the requirements of the grant agreement. Cause The Construction Financial Coordinator did not verify that all payrolls entered into LCP tracker.net were properly uploaded and certified in a timely manner. Repeat finding No Recommendation We recommend that policies and procedures be developed and implemented to ensure that certified payrolls are submitted properly and reviewed timely by the Construction Financial Coordinator. Management's response Management informed us that they agree with and will implement our recommendation.
Finding 2019 ? 003: During examination of six certified payrolls, it was noted that one payroll for Meadows Construction for the week ended December 25, 2018, was not properly submitted and, therefore, did not contain the contractor?s certification. After inquiry, this certified payroll was approved on October 28, 2019. Corrective Action: Management will implement the recommendation to develop policies and procedures to ensure that certified payrolls are submitted properly and reviewed timely by staff responsible for the task.
Federal program CFDA #20.205 Highway Planning and Construction CFDA #66.468 Capitalization Grants for Drinking Water State Revolving Funds Criteria or specific requirement When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non- Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/ (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition and context Per inquiry with the Manager Construction/Engineer on October 29, 2019, we were informed that the City did not perform a suspension and debarment check on two of the ten vendors selected for testing for the Highway Planning and Construction grant. We were also informed by the Utilities Financial Manager on December 2, 2019, that suspension and debarment checks were performed for six vendors examined for the Capitalization Grants for Drinking Water State Revolving Funds, however, documentation to support the check could not be provided. In addition, it was noted that in lieu of the check, a signed certification was not obtained from the vendors and a clause related to suspension and debarment was not included in the contract. A statistically valid sample was used Yes Questioned costs N/A Effect The City could have entered into transactions with vendors who are suspended or debarred from receiving federal funds resulting in non-compliance with State and Federal regulations. Cause The department experienced some staffing changes as a result of the City implementing staff alignment changes throughout the City. Additionally, personnel was not aware that they had to maintain documentation to indicate performance of procedures. Repeat finding No Recommendation We recommend that training be provided to all employees involved in the procurement process to ensure that they are aware of the requirements related to purchases using federal funds. Management's response Management informed us that training will be provided to all employees involved in the procurement process. In addition to checking for suspension and debarment, staff will maintain records to demonstrate compliance with all procurement policies.
Finding 2019 ? 004: During review/testing of suspension and debarment transactions and per inquiry with related Public Works and Utilities personnel, it was noted that suspension and debarment checks were either not completed in two of ten vendors tested and/or documentation could not be provided to substantiate the suspension and debarment checks had been completed. Corrective Action: Management will implement the recommendations to provide training to City employees involved in the procurement process to ensure that awareness exists for requirements related to purchases using federal funds and to retain substantiating documentation to support compliance with procurement requirements.
Federal program CFDA #11.300 Investments for Public Works and Economic Development Facilities CFDA # 14.218 Community Development Block Grants/Entitlement Grants CFDA #66.468 Capitalization Grants for Drinking Water State Revolving Funds Criteria or specific requirement The schedule of expenditures of federal awards (SEFA) shall be complete and accurate and agree to supporting records/documentation. Condition and context During the reconciliation of current year expenditures to the SEFA, we noted that the expenditures for the Investments for Public Works and Economic Development Facilities grant was understated by $498,772 due to the grantor increasing the reimbursement rate from 40% to 50% of expenses. The new rate was not communicated to finance and therefore the SEFA was not updated. In addition, the expenditures for the Community Development Block Grants/Entitlement Grants was overstated by $2,992 as a result of a duplicate entry in the general ledger. It was also noted that the expenditures for the Capitalization Grants for Drinking Water State Revolving Funds was overstated by $229,038 (included $238,386 of FY18 costs and excluded $9,348 of FY19 costs) due to using the "Item date" column versus the "GL date" column from the system generated report. A statistically valid sample was used Yes Questioned costs N/A Effect The fiscal 2019 SEFA was understated by $266,742 and did not agree to internal project records. Cause Failure to adopt, implement and monitor compliance with policies and procedures designed to provide reasonable assurance that the schedule of expenditures of federal awards is complete and accurate. Repeat finding, prior audit finding number Yes, 2018-007 Recommendation Management should adopt, implement and monitor compliance with policies and procedures designed to provide reasonable assurance that the schedule of expenditures of federal awards is complete and accurate. Additional resources should be made available to provide training and other resources to those delegated with the primary responsibility for grant compliance and the terms of the grants should be communicated to all personnel involved in administering federal grants. We recommend that management review the general ledger detail subsequent to year end and reimbursement requests received from subrecipients subsequent to year end to ensure that grant expenditures are recorded to the proper period for SEFA reporting purposes. Management's response Management informed us that they are implementing processes, including monthly monitoring, to ensure the schedule of expenditures of federal awards is complete and accurate. In connection with monthly monitoring, all involved personnel will be trained as to their responsibilities in this regard. Monthly monitoring will also included review / reconciliation of general ledger detail. In addition, subsequent to year end, reimbursement requests received from subrecipients will be reviewed to ensure that grant expenditures are recorded to the proper period for SEFA reporting purposes in agreement with general ledger details.
Finding 2019 ? 005: During review/reconciliation of current year expenditures to the SEFA, it was noted that the Investments for Public Works and Economic Development Facilities grant was understated by $498,772 due to the grantor increasing the reimbursement rate from 40% to 50% of actual expenses, Community Development Block Grants/Entitlement Grants was overstated by $2,992 due to a duplicate entry, and expenditures for the Capitalization Grants for Drinking Water State Revolving Funds were overstated by $2239,038. The resulting effect was that the SEFA was understated by $266,742 and did not agree to project records. Corrective Action: The City agrees with the recommendation to implement processes, including monthly monitoring to ensure the schedule of expenditures of federal awards is accurate. As part of monthly monitoring, all involved personnel will be trained as to their responsibilities in this regard. Monthly monitoring will also include review/reconciliation of general ledger detail. Additionally, subsequent to year-end, reimbursement requests received from sub-recipients will be reviewed to ensure that grant expenditures are recorded in the proper period for SEFA reporting purposes and in agreement with general ledger details.
2018-007
Federal program CFDA # 14.218 Community Development Block Grants/Entitlement Grants Criteria or specific requirement Financial reports are complete, accurate, and prepared in accordance with the required accounting basis. Reported amounts in performance or special reports agree to underlying data. U.S. Department of Housing and Urban Development (HUD) Report Instructions Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of each reporting period. Annual reports shall be submitted no later than 90 days after the end of each reporting period. Final reports shall be submitted no later than 90 days after the project or grant period end date. Condition and context Per examination of the Consolidated Annual Performance and Evaluation Report (CAPER) for program year 2018, it was noted that the amounts reported for persons served by ethnicity and household type did not agree to the underlying report data extracted from HUD's Intergrated Disbursement and Information System (IDIS). In addition, the quarterly federal financial reports (FFRs) were not filed timely during fiscal 2019 and the accounting basis for each was incorrectly identified as accrual basis even though the information was presented on the cash basis. A statistically valid sample was used No Questioned costs N/A Effect Reported amounts in the CAPER are not supported and the quarterly FFRs were not filed timely and did not indicate the correct accounting basis. Cause Lack of training of those responsible for reporting. Repeat finding No Recommendation We recommend that those charged with reporting responsibilities attend training specific to the grant and that they be given access to HUD resources. Management's response Management informed us that training will be provided to all staff members responsible for grant administration.
Finding 2019 ? 006: During examination of the CAPER for program year 2018, it was noted that the amounts reported for persons served by ethnicity and household type didn?t agree to the underlying report data extracted from HUD?s Integrated Disbursement and Information System (IDIS). Additionally, quarterly federal financial reports were not filed timely during fiscal year 2019 and the accounting basis for each was incorrectly identified as accrual basis although the presentation was cash basis. Corrective Action: Management agrees with the recommendation to ensure proper training is provided to all staff members responsible for grant administration.
Federal program CFDA #14.239 Home Investment Partnerships Program Criteria or specific requirement Per the City's contract with Clark County (the County), the City will report upon receipt of all program income earned from HOME funded projects within its respective jurisdiction and will forward all program income within 30 days to the County. Condition and context One out of 14 program income receipts examined was not submitted to Clark County within 30 days of receipt as required by the grant agreement. A statistically valid sample was used No Questioned costs N/A Effect The City is not in compliance with their grant agreements with Clark County. Cause Repeat finding, prior audit finding number Yes, 2018-005 Recommendation Program income received by the City may not be readily identifiable to a HOME project, may be missing proper supporting documentation, or may be for incorrect payoff amounts. As a result, we recommend that the grant accountant research each receipt to determine the proper application of such, a process that may occur over 30 days and approach the remittance deadline of the County. Management's response Management informed us that the recommended research process will be implemented.
Finding 2019 ? 007: During examination of 14 program income receipts received by the City, it was noted that 1 of the receipts were not submitted to the County within 30 days as required by the grant agreement. Corrective Action: Management will implement the recommendation that the grant accountant research each receipt to determine the proper application of program income to be compliant with the 30 day remittance deadline of the County.
2018-005
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 17, 2019. 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 July 17, 2019, which was (2590 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2017-005
GSA_MIGRATION
GSA_MIGRATION
2017-006
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
2017-004
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 2, 2018. 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 July 2, 2018, which was (2970 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2016-004
GSA_MIGRATION
GSA_MIGRATION
2016-003
GSA_MIGRATION
GSA_MIGRATION
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 11, 2017. 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 July 11, 2017, which was (3326 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
2015-005
GSA_MIGRATION
GSA_MIGRATION
2015-003
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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