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City of ConcordLocal Government

EIN: 946000315

UEI: R18EUE4LETK7

Audited by: Maze & Associates

Oversight agency: 20 [Department of Transportation]

View federal awards & risk assessment →

Data as of August 28, 2026

City of Concord10 audit years14 findings3 repeat
10
Audit Years
14
Total Findings
3
Repeat Findings
$9.2M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$9,195,778 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 31, 2026. 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 1, 2026 (32 days from today).

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2025-001
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During our testing of payroll expenditures that were charged to the grant, we noted one employee’s timecard included three hours of time charged to the grant for the payroll period ending May 11, 2025, however five hours were included in the documentation for the reimbursement request. Upon further discussion with City staff, we understand that due to turnover in the Public Works Department, reimbursement requests had been submitted to the grantor before they could be reviewed by the Finance Department. As a result, the amount requested for reimbursement from the grantor was more than was supported by employee payroll information and timesheets. In Finance Department discussions with the Public Works Department, it was determined that the Finance Department would be able to see that the timesheets of staff that worked on the grant would support the amounts included in the reimbursement request, so Finance staff recorded a journal entry in the amount of $85,762, of which $69,121 was to record the payroll and benefits from the reimbursement request in the grant accounts. However, upon further investigation and discussions with the grantor, Finance staff determined that the timesheets did not appear to support the charges. We further understand that City staff are in discussions with the grantor on how to handle the issue, whether it be through funds being returned to the grantor or a credit on a future reimbursement request. Effect: Payroll and benefit expenditures charged to the grant may be overstated. Cause: We understand that due to turnover in Public Works Department staff, the Finance Department was not made aware of the issue until after some of the reimbursement requests had been submitted and reimbursed by the grantor. Questioned Costs: We question costs in the amount of $69,121, representing the payroll and benefits costs that were added to the grant expenditures, without being supported by payroll documentation. Recommendation: The City should work with the grantor to determine how to resolve the issue. The City should also develop a process with the Public Works Department to ensure that actual payroll and benefits are charged to the grant and that those costs are supported by underlying payroll documents such as timesheets. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

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Finding #SA2025-001: Supporting Documentation for Payroll Expenditures Assistance Listing Number: 10.727 Assistance Listing Title: Inflation Reduction Act Urban & Community Forestry Program Name of Federal Agency: Department of Agriculture Pass Through Entity: The Trust for Public Land Federal Award Identification Number: 24-CA-11132544-011 Criteria: Payroll expenditures charged to a grant based on hours worked should be supported by the employees’ approved timesheets. In addition, reimbursement requests made to the grantor should be supported by the hours from the timesheets and other underlying payroll records, such as the costs of employee benefits. Condition: During our testing of payroll expenditures that were charged to the grant, we noted one employee’s timecard included three hours of time charged to the grant for the payroll period ending May 11, 2025, however five hours were included in the documentation for the reimbursement request. Upon further discussion with City staff, we understand that due to turnover in the Public Works Department, reimbursement requests had been submitted to the grantor before they could be reviewed by the Finance Department. As a result, the amount requested for reimbursement from the grantor was more than was supported by employee payroll information and timesheets. In Finance Department discussions with the Public Works Department, it was determined that the Finance Department would be able to see that the timesheets of staff that worked on the grant would support the amounts included in the reimbursement request, so Finance staff recorded a journal entry in the amount of $85,762, of which $69,121 was to record the payroll and benefits from the reimbursement request in the grant accounts. However, upon further investigation and discussions with the grantor, Finance staff determined that the timesheets did not appear to support the charges. We further understand that City staff are in discussions with the grantor on how to handle the issue, whether it be through funds being returned to the grantor or a credit on a future reimbursement request. Effect: Payroll and benefit expenditures charged to the grant may be overstated. Cause: We understand that due to turnover in Public Works Department staff, the Finance Department was not made aware of the issue until after some of the reimbursement requests had been submitted and reimbursed by the grantor. Questioned Costs: We question costs in the amount of $69,121, representing the payroll and benefits costs that were added to the grant expenditures, without being supported by payroll documentation. Recommendation: The City should work with the grantor to determine how to resolve the issue. The City should also develop a process with the Public Works Department to ensure that actual payroll and benefits are charged to the grant and that those costs are supported by underlying payroll documents such as timesheets. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

Finding #SA2025-001: Supporting Documentation for Payroll Expenditures Assistance Listing Number: 10.727 Assistance Listing Title: Inflation Reduction Act Urban & Community Forestry Program Name of Federal Agency: Department of Agriculture Pass Through Entity: The Trust for Public Land Federal Award Identification Number: 24-CA-11132544-011 • Fiscal Year of Initial Finding: 2025 • Name(s) of the contact person: Suzanne McDonald, Controller, and Alex Diosdado, City Urban Forester • Corrective Action Plan: City management agrees with this recommendation. City staff are working with the grantor to address how to correct the past reimbursement requests. New staff have been assigned to this grant and staff from the Public Works and Finance departments have developed processes to ensure that all costs charged to the project have the proper supporting documentation. • Anticipated Completion Date: June 30, 2026

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2025-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The City requested reimbursement for the full amount of budgeted indirect costs in the amount of $29,800 on the first reimbursement request. Although it was paid by the grantor, it does not appear to be an allowable cost as the City had not incurred direct costs at that time to warrant such a charge. As of June 30, 2025, the City had requested reimbursement for direct costs totaling $218,535, which means indirect costs totaling only $6,712 (3.1%) should have been requested. Effect: The City requested reimbursement for indirect costs in excess of the ratio of 3.1% of direct costs incurred at the time of reimbursement and direct costs as of June 30, 2025. Cause: We understand City staff responsible for preparing the grant reimbursement requests did not realize the indirect costs should be requested as the grant costs were incurred. Questioned Costs: We question costs in the amount of $23,088, which represent the costs in excess of the 3.1% of direct costs incurred. Recommendation: The City should ensure that staff responsible for preparing and reviewing reimbursement requests are familiar with the Uniform Guidance and grant guidelines. Costs requested for reimbursement should be based on actual costs incurred, including the reimbursement for indirect costs, unless the grant agreement indicates otherwise. The City should also work with the grantor to determine if the excess costs should be returned to the grantor or included as a reduction on a future reimbursement request. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

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Finding #SA2025-002: Indirect Costs in Excess of Costs Incurred Assistance Listing Number: 10.727 Assistance Listing Title: Inflation Reduction Act Urban & Community Forestry Program Name of Federal Agency: Department of Agriculture Pass Through Entity: The Trust for Public Land Federal Award Identification Number: 24-CA-11132544-011 Criteria: Appendix B, Subrecipient Information, 2 CFR 200.332(a)(1), of the grant agreement for the Inflation Reduction Act Urban & Community Forestry Program provides for an “Indirect cost rate for the Federal award (including if the de minimis rate is charged) per 2CFR 200.414: 12%, however the grant award budget includes a provision for indirect costs of $29,800. Although the grant award budget indicates the costs use a rate of 2.98%., it calculates to a rate of 3.1% of direct costs. Condition: The City requested reimbursement for the full amount of budgeted indirect costs in the amount of $29,800 on the first reimbursement request. Although it was paid by the grantor, it does not appear to be an allowable cost as the City had not incurred direct costs at that time to warrant such a charge. As of June 30, 2025, the City had requested reimbursement for direct costs totaling $218,535, which means indirect costs totaling only $6,712 (3.1%) should have been requested. Effect: The City requested reimbursement for indirect costs in excess of the ratio of 3.1% of direct costs incurred at the time of reimbursement and direct costs as of June 30, 2025. Cause: We understand City staff responsible for preparing the grant reimbursement requests did not realize the indirect costs should be requested as the grant costs were incurred. Questioned Costs: We question costs in the amount of $23,088, which represent the costs in excess of the 3.1% of direct costs incurred. Recommendation: The City should ensure that staff responsible for preparing and reviewing reimbursement requests are familiar with the Uniform Guidance and grant guidelines. Costs requested for reimbursement should be based on actual costs incurred, including the reimbursement for indirect costs, unless the grant agreement indicates otherwise. The City should also work with the grantor to determine if the excess costs should be returned to the grantor or included as a reduction on a future reimbursement request. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

Finding #SA2025-002: Indirect Costs in Excess of Costs Incurred Assistance Listing Number: 10.727 Assistance Listing Title: Inflation Reduction Act Urban & Community Forestry Program Name of Federal Agency: Department of Agriculture Pass Through Entity: The Trust for Public Land Federal Award Identification Number: 24-CA-11132544-011 • Fiscal Year of Initial Finding: 2025 • Name(s) of the contact person: Suzanne McDonald, Controller, and Alex Diosdado, City Urban Forester • Corrective Action Plan: City management agrees with this recommendation. City staff are working with the grantor to address how to correct the past reimbursement requests. New staff have been assigned to this grant and staff from the Public Works and Finance departments have developed processes to ensure that all costs charged to the project have the proper supporting documentation. • Anticipated Completion Date: June 30, 2026

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FY 2024-06-30

$15,930,075 federal awards expended

FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.

2024-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-002OTHER MATTERS

We noted that the City had two subawards during fiscal year 2024 that were larger than $30,000. For the subaward under B-23-MC-06-0009, we noted the subgrant agreement in the amount of $505,417 was reported incorrectly as $305,417 in the FSRS. For the subaward in the subaward under COVID-19 – B-20-MW-06-0009, the agreement in April 2020 in the amount of $378,780 was amended in August 2023 to increase the contract to $689,352, but City staff was not able to provide documentation that the original or amended subaward was reported in the FSRS. Cause: We understand that the error was a typo that went unnoticed. For the failure to report for the CDBG-CV program, we understand City staff thought the reporting was not required, since the subgrant was originally executed in fiscal year 2020. Effect: The City is not in compliance with the FFATA reporting requirements. Identification as a repeat finding: Yes, since 2022 Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

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Finding Reference Number: SA2024-001 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-23-MC-06-0009 COVID-19 – B-20-MW-06-0009 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 that are codified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subawards that are entered into the FSRS System should be maintained so that any amendments to the subawards are also reflected in the system. Condition: We noted that the City had two subawards during fiscal year 2024 that were larger than $30,000. For the subaward under B-23-MC-06-0009, we noted the subgrant agreement in the amount of $505,417 was reported incorrectly as $305,417 in the FSRS. For the subaward in the subaward under COVID-19 – B-20-MW-06-0009, the agreement in April 2020 in the amount of $378,780 was amended in August 2023 to increase the contract to $689,352, but City staff was not able to provide documentation that the original or amended subaward was reported in the FSRS. Cause: We understand that the error was a typo that went unnoticed. For the failure to report for the CDBG-CV program, we understand City staff thought the reporting was not required, since the subgrant was originally executed in fiscal year 2020. Effect: The City is not in compliance with the FFATA reporting requirements. Identification as a repeat finding: Yes, since 2022 Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

Finding Reference Number: SA2024-001 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-23-MC-06-0009 COVID-19 – B-20-MW-06-0009 • Fiscal Year of Initial Finding: 2022 • Name(s) of the contact person: Suzanne McDonald, Finance Operations Manager and Brenda Kain, Interim Community Services Manager • Corrective Action Plan: Management concurs with this recommendation. As of October 2024, the city has new staff managing the CDBG program. This staff will be trained on the FFATA reporting requirements and on how to meet those reporting requirements using the new SAM.gov/fsfr reporting platform. • Anticipated Completion Date: Calendar Year 2025

Prior Finding References

2023-002

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FY 2023-06-30

LOW-RISK AUDITEE$14,337,637 federal awards expended

FAC accepted this audit on April 1, 2024 — management decision was due October 1, 2024.

2023-001
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

Due to employee turnover in the Purchasing Department the City was unable to provide support showing that suspension and debarment checks were being completed during the fiscal year. However, we understand that subsequent to year end the City has implemented procedures for the documentation of the suspension and debarment checks. Cause: Due to turnover in staffing, the City was not able to provide support showing that the City was in compliance with the requirement to verify the status of contractors prior to entering into agreements with the entities. Effect: The City is not in compliance with the award terms and conditions and the OMB Compliance Supplement requirements of the Coronavirus State and Local Fiscal Recovery Funds program. Identification as a repeat finding: Yes, since 2022 Recommendation: We understand the City has developed procedures to ensure compliance with debarment and suspension provisions of the grant award terms and conditions and the OMB Compliance Supplement of the Coronavirus State and Local Fiscal Recovery Funds program subsequent to fiscal year 2023. However, the City should develop procedures to ensure compliance with grant award conditions prior to expending funds. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

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Finding Reference Number: SA2023-001 - Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP0424 Criteria: The award terms and conditions of the Coronavirus State and Local Fiscal Recovery Funds agreement with the Department of the Treasury requires that the City comply with OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), 2 C.F.R. Part 180, including the requirement to include a term or condition in all lower tier covered transactions (contracts and subcontracts described in 2 C.F.R. Part 180, subpart B) that the award is subject to 2 C.F.R. Part 180 and Treasury’s implementing regulation at 31 C.F.R. Part 19. In addition, the OMB Compliance Supplement for the Program requires that prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: Due to employee turnover in the Purchasing Department the City was unable to provide support showing that suspension and debarment checks were being completed during the fiscal year. However, we understand that subsequent to year end the City has implemented procedures for the documentation of the suspension and debarment checks. Cause: Due to turnover in staffing, the City was not able to provide support showing that the City was in compliance with the requirement to verify the status of contractors prior to entering into agreements with the entities. Effect: The City is not in compliance with the award terms and conditions and the OMB Compliance Supplement requirements of the Coronavirus State and Local Fiscal Recovery Funds program. Identification as a repeat finding: Yes, since 2022 Recommendation: We understand the City has developed procedures to ensure compliance with debarment and suspension provisions of the grant award terms and conditions and the OMB Compliance Supplement of the Coronavirus State and Local Fiscal Recovery Funds program subsequent to fiscal year 2023. However, the City should develop procedures to ensure compliance with grant award conditions prior to expending funds. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

Finding Reference Number: SA2023-001 - Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP0424 • Fiscal Year of Initial Finding: 2022 • Name(s) of the contact person: Purchasing Manager • Corrective Action Plan: The purchasing division consists of (2) staff members. The division had turn over in both purchasing positions during fiscal year 2022/23. During this time, the documentation of disbarment checks by purchasing staff was not consistent. To strengthen this process, the City put multiple checks in place to ensure that City staff is aware of this requirement and is meeting this requirement: 1. Every Request for Proposal request that vendors certify that they are not on the exclusion list as part of the bidding or solicitation process. 2. When preparing a Request for a Purchase Order, departments have a checklist of "Required Documentation" to support the Requisition. A section has been added to check if the purchase will be funded by federal funds and, if yes, the department is to provide a screen shot of the disbarment check from sam.gov. 3. The REQUISITION/PO tracking sheet used by the Purchasing Account Clerk includes a column to mark that the disbarment check has been completed. 4. The instructions in the Purchasing Acct Clerk desk manual include instructions on how to complete a disbarment check as part of the "Creating a PO" script. • Anticipated Completion Date: June 30, 2024

Prior Finding References

2022-001

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2023-002
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-002OTHER MATTERS

We noted that the City had three subawards during fiscal year 2023 that were larger than $30,000, but City staff was not able to provide documentation that the subawards were reported in the FSRS. Cause: We understand that program staff received training on FFATA reporting requirements late in fiscal year 2023 and is updating their policies to comply with the requirements in fiscal year 2024. Effect: The City is not in compliance with the FFATA reporting requirements. Identification as a repeat finding: Yes, since 2022 Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

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Finding Reference Number: SA2023-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-22-MC-06-0009 COVID-19 – B-20-MW-06-0009 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 that are codified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subawards that are entered into the FSRS System should be maintained so that any amendments to the subawards are also reflected in the system. Condition: We noted that the City had three subawards during fiscal year 2023 that were larger than $30,000, but City staff was not able to provide documentation that the subawards were reported in the FSRS. Cause: We understand that program staff received training on FFATA reporting requirements late in fiscal year 2023 and is updating their policies to comply with the requirements in fiscal year 2024. Effect: The City is not in compliance with the FFATA reporting requirements. Identification as a repeat finding: Yes, since 2022 Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

Finding Reference Number: SA2023-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-22-MC-06-0009 COVID-19 – B-20-MW-06-0009 • Fiscal Year of Initial Finding: 2022 • Name(s) of the contact person: Leng Powers • Corrective Action Plan: In April 2023, City staff received training on the FFATA website and reporting requirements. After review of the website, the website's requirements, and the FFATA reporting requirements, City staff assigned reporting roles to individuals in Housing and Finance to report within 30 days of executing agreements of $30,000 with sub-recipients. During Fiscal Year 2022/23, the City entered into contract with (3) sub-recipients for awards over $30,000. These contracts were officially executed in December2022/January 2023. The City has been working to obtain the UEI and other miscellaneous reporting information from the sub-recipients in order to complete the required FFATA report for FY2022-23. Going forward, the City will require the FFATA information to be included in the sub-awardee prior to executing the grant award. • Anticipated Completion Date: June 30, 2024

Prior Finding References

2022-002

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FY 2022-06-30

LOW-RISK AUDITEE$8,334,512 federal awards expended

FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.

2022-001
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

We selected two contracts for testing and noted that City did not include a term or condition related to compliance with debarment and suspension compliance provisions and we understand that the City did not verify the contractors and subrecipient were not suspended, debarred, or otherwise excluded prior to entering into the agreements. We did note that as of March 28, 2023, the two vendors were not included on the exclusions list on SAM.gov. Cause: We understand that due to turnover in staffing, the City was not able to provide support showing that the City was in compliance with the requirement to verify the status of contractors prior to entering into agreements with the entities. Effect: The City is not in compliance with the award terms and conditions and the OMB Compliance Supplement requirements of the Coronavirus State and Local Fiscal Recovery Funds program. Recommendation: The City should develop procedures to ensure compliance with debarment and suspension provisions of the grant award terms and conditions and the OMB Compliance Supplement of the Coronavirus State and Local Fiscal Recovery Funds program. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

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Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP0424 Criteria: The award terms and conditions of the Coronavirus State and Local Fiscal Recovery Funds agreement with the Department of the Treasury requires that the City comply with OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), 2 C.F.R. Part 180, including the requirement to include a term or condition in all lower tier covered transactions (contracts and subcontracts described in 2 C.F.R. Part 180, subpart B) that the award is subject to 2 C.F.R. Part 180 and Treasury?s implementing regulation at 31 C.F.R. Part 19. In addition, the OMB Compliance Supplement for the Program requires that prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We selected two contracts for testing and noted that City did not include a term or condition related to compliance with debarment and suspension compliance provisions and we understand that the City did not verify the contractors and subrecipient were not suspended, debarred, or otherwise excluded prior to entering into the agreements. We did note that as of March 28, 2023, the two vendors were not included on the exclusions list on SAM.gov. Cause: We understand that due to turnover in staffing, the City was not able to provide support showing that the City was in compliance with the requirement to verify the status of contractors prior to entering into agreements with the entities. Effect: The City is not in compliance with the award terms and conditions and the OMB Compliance Supplement requirements of the Coronavirus State and Local Fiscal Recovery Funds program. Recommendation: The City should develop procedures to ensure compliance with debarment and suspension provisions of the grant award terms and conditions and the OMB Compliance Supplement of the Coronavirus State and Local Fiscal Recovery Funds program. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP0424 ? Fiscal Year of Initial Finding: 2022 ? Name(s) of the contact person: Purchasing Manager ? Corrective Action Plan: Pursuant to Section 25 (Debarment /Suspension Policy) of the City of Concord Purchase Order Contract delineates this. Specifically, in City of Concord Contracting the process would be to check with the Federal Government Debarment Database/SAM.gov to ensure the contractor has not been suspended or debarred. Once this step is complete, verification is documented in the file and the contract would be awarded. The City will ensure this takes place going forward and documentation is retained. ? Anticipated Completion Date: April 30, 2023

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2022-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

We noted that the City had two subawards during fiscal year 2022 that were than $30,000, but City staff was not able to provide documentation that the subawards were reported in the FSRS. Cause: We understand that program staff were not familiar with the FFATA reporting requirements. Effect: The City is not in compliance with the FFATA reporting requirements. Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

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Finding Reference Number: SA2022-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 that are codified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subawards that are entered into the FSRS System should be maintained so that any amendments to the subawards are also reflected in the system. Condition: We noted that the City had two subawards during fiscal year 2022 that were than $30,000, but City staff was not able to provide documentation that the subawards were reported in the FSRS. Cause: We understand that program staff were not familiar with the FFATA reporting requirements. Effect: The City is not in compliance with the FFATA reporting requirements. Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

Finding Reference Number: SA2022-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 ? Fiscal Year of Initial Finding: 2022 ? Name(s) of the contact person: Leng Powers ? Corrective Action Plan: The City has identified all first-tier sub-award agreements of $30,000 or more and will ensure that new staff has access to the FSFR reporting system to review prior reporting and ensure continued reporting compliance with the FFATA requirements. ? Anticipated Completion Date: April 30, 2023

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2022-003
Reporting / Other
SIGNIFICANT DEFICIENCYOTHER MATTERS

We obtained the City?s PR26 ? CDBG Financial Summary Report for program year 2021 (fiscal year ended June 30, 2022), which reported program expenditures of $1,927,639. We requested a reconciliation of that amount on the PR26 to the program expenditures reported on the SEFA of $963,820, but City staff could not reconcile the amounts reported. It appears that the program expenditures in the PR26 ? CDBG Financial Summary Report were doubled, as the amount on the SEFA is exactly half of that amount. We were not able to test the components of the PR26 ? CDBG-CV Financial Summary Report for fiscal year 2022, because City staff did not retain a copy of the report and was not able to extract a copy from the Integrated Disbursement and Information System (IDIS). Finally, City staff was not able to locate copies of the Funding/Approval Agreements for CDBG and CDBG-CV for the periods starting July 1, 2021 and June 30, 2020, respectively. Those Agreements not only contain the grant award amount, they include special award terms and conditions. Cause: We understand that City staff had worked with the grantor to make corrections to the PR26 ? CDBG Financial Summary Report, but could not provide us with documentation to show that the corrections made were related to the program expenditures. For the PR26 ? CDBG-CV Financial Summary Report, we understand City staff did not retain a copy of the report and were unable to generate a copy of the report from the IDIS system. For the Funding/Approval Agreements, due to staff turnover, City staff could not locate copies of the award agreements. Effect: The City is not in compliance with the financial reporting requirements of the CDBG Program and may not be in compliance with special award terms and conditions of the program. Recommendation: The City should develop procedures to ensure that financial reports filed in the IDIS system reconcile with general ledger activity and amounts reported on the SEFA. The City should also ensure that grant reports and grant award information is retained in the City?s files. Finally, the City should obtain copies of the Funding/Approval Agreements for the program to ensure that it is aware of all special award terms and conditions. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

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Finding Reference Number: SA2022-003 - Financial Reporting and Retention of Grant Documentation Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Grantees may include reports generated by Integrated Disbursement and Information System (IDIS) as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. The reports to be included in the annual performance and evaluation report include the PR26 ? CDBG Financial Summary Report and the PR26 ? CDBG-CV Financial Summary Report. The reports should include accurate information and reconcile to the amounts reported on the SEFA. In addition, one component of the PR26 ? CDBG Financial Summary Report (line 02) and the PR26 ? CDBG-CV Financial Summary Report (line 01) is the grant award amount. That information is directly from the City?s annual Funding Approval/Agreement. Condition: We obtained the City?s PR26 ? CDBG Financial Summary Report for program year 2021 (fiscal year ended June 30, 2022), which reported program expenditures of $1,927,639. We requested a reconciliation of that amount on the PR26 to the program expenditures reported on the SEFA of $963,820, but City staff could not reconcile the amounts reported. It appears that the program expenditures in the PR26 ? CDBG Financial Summary Report were doubled, as the amount on the SEFA is exactly half of that amount. We were not able to test the components of the PR26 ? CDBG-CV Financial Summary Report for fiscal year 2022, because City staff did not retain a copy of the report and was not able to extract a copy from the Integrated Disbursement and Information System (IDIS). Finally, City staff was not able to locate copies of the Funding/Approval Agreements for CDBG and CDBG-CV for the periods starting July 1, 2021 and June 30, 2020, respectively. Those Agreements not only contain the grant award amount, they include special award terms and conditions. Cause: We understand that City staff had worked with the grantor to make corrections to the PR26 ? CDBG Financial Summary Report, but could not provide us with documentation to show that the corrections made were related to the program expenditures. For the PR26 ? CDBG-CV Financial Summary Report, we understand City staff did not retain a copy of the report and were unable to generate a copy of the report from the IDIS system. For the Funding/Approval Agreements, due to staff turnover, City staff could not locate copies of the award agreements. Effect: The City is not in compliance with the financial reporting requirements of the CDBG Program and may not be in compliance with special award terms and conditions of the program. Recommendation: The City should develop procedures to ensure that financial reports filed in the IDIS system reconcile with general ledger activity and amounts reported on the SEFA. The City should also ensure that grant reports and grant award information is retained in the City?s files. Finally, the City should obtain copies of the Funding/Approval Agreements for the program to ensure that it is aware of all special award terms and conditions. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

Corrective Action Plan

Finding Reference Number: SA2022-003 - Financial Reporting and Retention of Grant Documentation Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 ? Fiscal Year of Initial Finding: 2022 ? Name(s) of the contact person: Leng Powers ? Corrective Action Plan: The City will develop procedures to ensure that the PR26 ties to the general ledger before submission and the City will retain all future PR 26 reports in a centralized location in the City?s files. In addition, the City will retain all future CDBG agreements in a centralized location in the City?s files. ? Anticipated Completion Date: April 30, 2023

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FY 2021-06-30

LOW-RISK AUDITEE$8,728,083 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 10, 2022 — management decision was due October 10, 2022.

FY 2020-06-30

LOW-RISK AUDITEE$1,732,336 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.

FY 2019-06-30

LOW-RISK AUDITEE$1,981,506 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 30, 2020 — management decision was due September 30, 2020.

FY 2018-06-30

LOW-RISK AUDITEE$2,869,041 federal awards expended

FAC accepted this audit on January 17, 2019 — management decision was due July 17, 2019.

2018-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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FY 2017-06-30

LOW-RISK AUDITEE$4,349,096 federal awards expended

FAC accepted this audit on December 18, 2017 — management decision was due June 18, 2018.

2017-001
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-002
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-003
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-004
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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FY 2016-06-30

LOW-RISK AUDITEE$4,375,508 federal awards expended

FAC accepted this audit on January 18, 2017 — management decision was due July 18, 2017.

2016-002
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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