EIN: 946000410
UEI: KJNSFMC9KVD5
Audited by: Macias Gini & O'Connell LLP
Oversight agency: 20 [Department of Transportation]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 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 September 30, 2026 (26 days from today).
What is a management decision? →FAC accepted this audit on March 26, 2025 — management decision was due September 26, 2025.
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
While the City has a process in place for verifying that the person is not excluded or disqualified, we noted that two out of the three contract agreements reviewed did not include a suspension and debarment certification clause indicating the contractor was not suspended or debarred from participation in federally funded contracts. There was no other documentation available to demonstrate that the verification of suspension and debarment was performed prior to entering into the covered transactions. Based on subsequent review of the System for Award Management (SAM) exclusions, the two contractors were not suspended or debarred. Cause: Through inquiry of City personnel, the department responsible for administering the program does not regularly handle federally funded programs and were not made aware of the suspension and debarment requirements. Effect: Failure to verify suspension and debarment results in noncompliance with 2 CFR ?180.300, as well as a risk that federal funds could be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs: No questioned costs were identified. Context: The federal funds disbursed to vendors for the fiscal year ended June 30, 2022 totaled $1,486,507. Three vendor contracts were selected for testing. Disbursements made under the three vendor contracts totaled $1,389,548. For two of the three vendor contracts, there was no evidence that verification of suspension and debarment was performed prior to entering into the covered transactions. Total disbursements made associated with the two vendor contracts was $392,500 for the fiscal year ended June 30, 2022. Recommendation: We recommend that when the City enters into arrangements involving federal funds and the administration of federal programs, departments and the personnel responsible for carrying out the objectives of the programs are trained and knowledgeable of the laws, regulations, terms and conditions governing the federal program. Furthermore, we recommend that prior to entering into covered transactions with vendors involving federal funds, the City should establish a process for verifying through SAM whether the vendors are suspended or debarred, maintaining of the verification documentation, or adding a clause into the vendor contract providing for the vendor certification of their suspension or debarment status. Views of Responsible Officials and Corrective Action Plan: Management?s response is reported in ?Management?s Response and Corrective Action Plan? included in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴Reference Number: 2022-001 Category of Finding: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency and Instance of Noncompliance Federal Agency: U.S. Department of Housing and Urban Development Federal Assistance Listing Number: 14.889 Federal Program Title: Choice Neighborhoods Implementation Grants Federal Award Number and Year: CA9G007CNG114; 2015 Criteria: Title 2 - Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management ?200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter I - Office of Management and Budget Governmentwide Guidance for Grants and Agreements. Part 180 ? OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Non-procurement). Subpart C ? Responsibilities of Participants Regarding Transactions Doing Business With Other Persons ?180.300 (2 CFR 180.300): When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom they intend to do business is not excluded or disqualified. You may do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or a condition to the covered transaction with that person. Condition: While the City has a process in place for verifying that the person is not excluded or disqualified, we noted that two out of the three contract agreements reviewed did not include a suspension and debarment certification clause indicating the contractor was not suspended or debarred from participation in federally funded contracts. There was no other documentation available to demonstrate that the verification of suspension and debarment was performed prior to entering into the covered transactions. Based on subsequent review of the System for Award Management (SAM) exclusions, the two contractors were not suspended or debarred. Cause: Through inquiry of City personnel, the department responsible for administering the program does not regularly handle federally funded programs and were not made aware of the suspension and debarment requirements. Effect: Failure to verify suspension and debarment results in noncompliance with 2 CFR ?180.300, as well as a risk that federal funds could be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs: No questioned costs were identified. Context: The federal funds disbursed to vendors for the fiscal year ended June 30, 2022 totaled $1,486,507. Three vendor contracts were selected for testing. Disbursements made under the three vendor contracts totaled $1,389,548. For two of the three vendor contracts, there was no evidence that verification of suspension and debarment was performed prior to entering into the covered transactions. Total disbursements made associated with the two vendor contracts was $392,500 for the fiscal year ended June 30, 2022. Recommendation: We recommend that when the City enters into arrangements involving federal funds and the administration of federal programs, departments and the personnel responsible for carrying out the objectives of the programs are trained and knowledgeable of the laws, regulations, terms and conditions governing the federal program. Furthermore, we recommend that prior to entering into covered transactions with vendors involving federal funds, the City should establish a process for verifying through SAM whether the vendors are suspended or debarred, maintaining of the verification documentation, or adding a clause into the vendor contract providing for the vendor certification of their suspension or debarment status. Views of Responsible Officials and Corrective Action Plan: Management?s response is reported in ?Management?s Response and Corrective Action Plan? included in a separate section at the end of this report.
FINDING 2022-001 Views of Responsible Officials and Corrective Action: We concur. Due to the finding that Convention and Cultural Services Department agreements did not contain a certification clause indicating the contractor was not suspended or debarred and other documentation was lacking to demonstrate verification had been obtained prior to performance of an agreement, the Convention and Cultural Services Department will develop procedures outlining the requirement to use the SAM.gov (excluded Parties List System) database, require the vendor to provide proper certification, or include specific language in agreements to verify that any vendors who may be awarded a contract or submit invoices for federal grant-funded activities have not been debarred or suspended. Implementation Date: April 2023 Name of Responsible Person: Donald Gensler, APP Project Manager, Office of Arts + Culture
FAC accepted this audit on March 29, 2022 — management decision was due September 29, 2022.
While the City has a process in place to perform risk assessments and monitor subrecipients, there was no formal documentation of these activities being performed. Out of 22 subrecipients tested, there were nine instances in which evidence of a risk assessment and/or the monitoring of subrecipients was not available. Cause: Through inquiry of City personnel, City management communicated to project managers, whom are responsible for conducting subrecipient risk assessments and performing monitoring procedures, the importance of retaining evidence of the risk assessments and monitoring. However, although project managers performed the required risk assessment and monitoring, evidence of the actual work performed was not consistently retained. Effect: In the absence of a formally documented risk assessment and monitoring process for determining appropriate monitoring procedures, including document retention, sufficient and effective monitoring may not occur for those subrecipients most at risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. Questioned Costs: No questioned costs were identified. Context: Disbursements to subrecipients for the Coronavirus Relief Fund program for the fiscal year ended June 30, 2021, totaled $34,850,625. The total amount passed through to the 22 subrecipients tested was $19,599,318. Recommendation: City departments that pass through federal funds to subrecipients should have a formally documented process for performing risk assessments over its subrecipients, including document retention, which guides the frequency and extent of monitoring activities to be performed. Views of Responsible Officials and Corrective Action Plan: Management?s response is reported in ?Management?s Response and Corrective Action Plan? included in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴Reference Number: 2021-001 Category of Finding: Subrecipient Monitoring Type of Finding: Significant Deficiency and Instance of Noncompliance Federal Agency: U.S. Department of the Treasury Federal Assistance Listing Number: 21.019 Federal Program Title: COVID-19 Coronavirus Relief Fund Federal Award Year: 2020 Criteria: Title 2 - Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management ?200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements Standards for Financial and Program Management. Subrecipient Monitoring and Management. ?200.332 Requirements for pass-through entities (2 CFR 200.332): All pass-through entities must: (b) Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient?s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management decision. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the passthrough entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ?200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (d) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ?200.425. Condition: While the City has a process in place to perform risk assessments and monitor subrecipients, there was no formal documentation of these activities being performed. Out of 22 subrecipients tested, there were nine instances in which evidence of a risk assessment and/or the monitoring of subrecipients was not available. Cause: Through inquiry of City personnel, City management communicated to project managers, whom are responsible for conducting subrecipient risk assessments and performing monitoring procedures, the importance of retaining evidence of the risk assessments and monitoring. However, although project managers performed the required risk assessment and monitoring, evidence of the actual work performed was not consistently retained. Effect: In the absence of a formally documented risk assessment and monitoring process for determining appropriate monitoring procedures, including document retention, sufficient and effective monitoring may not occur for those subrecipients most at risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. Questioned Costs: No questioned costs were identified. Context: Disbursements to subrecipients for the Coronavirus Relief Fund program for the fiscal year ended June 30, 2021, totaled $34,850,625. The total amount passed through to the 22 subrecipients tested was $19,599,318. Recommendation: City departments that pass through federal funds to subrecipients should have a formally documented process for performing risk assessments over its subrecipients, including document retention, which guides the frequency and extent of monitoring activities to be performed. Views of Responsible Officials and Corrective Action Plan: Management?s response is reported in ?Management?s Response and Corrective Action Plan? included in a separate section at the end of this report.
FINDING 2021-001 Management?s or Department?s Response: We concur. Views of Responsible Officials and Corrective Action: The City agrees that the absence of a formally documented risk assessment and monitoring process poses a risk of subrecipient noncompliance with federal statutes, regulations, and terms and conditions of the subaward. Moving forward, the City will develop and document a formal process for performing risk assessment and monitoring over subrecipients, including documentation requirements. The City will continue to educate project managers and emphasize the importance of documentation retention as procedures are performed. Note, that the City has spent all remaining Coronavirus Relief Fund program funding as of March 2022. No expenditures related to subrecipients were incurred for this program for fiscal year 2022. Implementation Date: March 2022 Name of Responsible Person: Ash Roughani
FAC accepted this audit on March 28, 2021 — management decision was due September 28, 2021.
FAC accepted this audit on March 29, 2020 — management decision was due September 29, 2020.
The Child Development Program (Program) did not stop providing subsidized child care and development program services to children who reached their thirteenth birthday, and the Program continued to certify and recertify children over thirteen at initial certification or recertification date. Cause: The Program has an internal policy to provide subsidized care for children up to the age of 14 or youth in sixth grade, despite their age. Effect: Providing subsidized child care services to ineligible children can result in improper attendance information, program income, and program expenses. Questioned Costs: Questioned costs were not identified. Context: During our review of the family data files for determining eligibility, we noted two out of the 15 children selected for testing, had reached their thirteenth birthday before the recertification date, but were still determined by the Program to be eligible for subsidized care and there were no exceptional needs identified. Recommendation: We recommend the Program consider changing its policy related to subsidized child care services to stop providing benefits to children who have reached the age of thirteen, except those children with exceptional needs, at initial certification or recertification in accordance with the Uniform Guidance requirements. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Title 2 - Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements, Standards for Financial and Program Management, ?200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 45 ? Public Welfare, Subtitle A ? Department of Health and Human Services ? Part 98, Child Care and Development Fund ? Subpart C ? Eligibility for Services ? ?98.20 ? A Child?s Eligibility for Child Care Services: (a) To be eligible for services under ?98.50, a child shall, at the time of eligibility determination or redetermination: (1) (i) Be under 13 years of age; or, (ii) At the option of the Lead Agency, be under age 19 and physically or mentally incapable of caring for himself or herself, or under court supervision; Condition: The Child Development Program (Program) did not stop providing subsidized child care and development program services to children who reached their thirteenth birthday, and the Program continued to certify and recertify children over thirteen at initial certification or recertification date. Cause: The Program has an internal policy to provide subsidized care for children up to the age of 14 or youth in sixth grade, despite their age. Effect: Providing subsidized child care services to ineligible children can result in improper attendance information, program income, and program expenses. Questioned Costs: Questioned costs were not identified. Context: During our review of the family data files for determining eligibility, we noted two out of the 15 children selected for testing, had reached their thirteenth birthday before the recertification date, but were still determined by the Program to be eligible for subsidized care and there were no exceptional needs identified. Recommendation: We recommend the Program consider changing its policy related to subsidized child care services to stop providing benefits to children who have reached the age of thirteen, except those children with exceptional needs, at initial certification or recertification in accordance with the Uniform Guidance requirements. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
Management?s or Department's Response We concur. Views of Responsible Officials and Corrective Action: We agree with the finding, however the City ended the federal program to subsidize child care services effective June 30, 2019. Therefore, we do not believe a corrective action is necessary. Name of Responsible Person: Not applicable. Implementation Date: Not applicable.
The National Urban Search and Rescue Response Program (Program) did not have proper segregation of duties in place to either prevent and/or detect the risk of noncompliance as it relates to the reporting compliance requirement. Cause: The Program experienced high turnover during the fiscal year and did not have sufficient staffing to properly segregate the preparation and review of the quarterly SF-425 financial reports. Effect: The Program may not be able to properly prevent or detect the risk of material noncompliance without proper segregation of duties between the preparation and review of financial reports. This lack of segregation of could result in the inaccurate or incomplete reporting of required data elements, such as Federal expenditures, recipient share of expenditures, and unobligated balance for each individual grant. Questioned Costs: N/A Context: During our review of the SF-425 financial reports, we noted three out of the five reports were prepared and submitted without a person independent of the preparation process reviewing the reports for accuracy and completeness. Recommendation: Where there is a lack of department resources, the Program could cross-train employees in the Depatment of Finance to perform an independent review of the SF-425 quarterly financial report. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
Show full finding ▾Hide full finding ▴Criteria:? Title 2 - Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements, Standards for Financial and Program Management, ?200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The National Urban Search and Rescue Response Program (Program) did not have proper segregation of duties in place to either prevent and/or detect the risk of noncompliance as it relates to the reporting compliance requirement. Cause: The Program experienced high turnover during the fiscal year and did not have sufficient staffing to properly segregate the preparation and review of the quarterly SF-425 financial reports. Effect: The Program may not be able to properly prevent or detect the risk of material noncompliance without proper segregation of duties between the preparation and review of financial reports. This lack of segregation of could result in the inaccurate or incomplete reporting of required data elements, such as Federal expenditures, recipient share of expenditures, and unobligated balance for each individual grant. Questioned Costs: N/A Context: During our review of the SF-425 financial reports, we noted three out of the five reports were prepared and submitted without a person independent of the preparation process reviewing the reports for accuracy and completeness. Recommendation: Where there is a lack of department resources, the Program could cross-train employees in the Depatment of Finance to perform an independent review of the SF-425 quarterly financial report. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
Federal Agency: United States Department of Homeland Security Category of Finding: Reporting Management?s or Department?s Response: We concur. Management's or Department's Response: We concur Views of Responsible Officials and Corrective Action Plan: Management agrees that cross-training additional employees in the fiscal division of the Department will allow for an independent review of the SF-425 quarterly financial report to check for accuracy and completeness prior to submission into the Federal Emergency Management Agency?s Payment and Reporting System. The Administrative Analyst will prepare supporting documents and provide the documents to the Program Manager and Grants Manager to review prior to entering information into the SF-425 in the Payment and Reporting System. The documents will include the signature of the Administrative Analyst as the preparer and the signatures of the Program Manager and the Grants Manager as approvers. After the documents have been reviewed, signed and approved, the Grants Manager will input the information into the SF-425 in the Payment and Reporting System. Name of Responsible Person: Carol Renix Implementation Date: March 2020
FAC accepted this audit on March 24, 2019 — management decision was due September 24, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on March 6, 2018 — management decision was due September 6, 2018.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on February 26, 2017 — management decision was due August 26, 2017.
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