Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 16, 2025. 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 November 16, 2025, which was (276 days ago).
What is a management decision? →Reference No.: 2024-001 – Timeliness in Financial Reporting Evaluation of Finding: Significant deficiency/material noncompliance. Criteria: Financial reports are intended to meet the needs of decision makers, including the governing board, bondholders, Federal and State oversight agencies, and constituents. Accordingly, timeliness was identified as one of the characteristics of information in financial reporting in GASB Concepts Statement No. 1 of the Governmental Accounting Standards Board (GASB), Objectives of Financial Reporting. To accomplish this objective, financial reports must be available in time for informed decision making. Therefore, financial reports should be published as soon as possible after the end of the reporting period. Assistance Listing Number Program Title Federal Agency Pass-Through Entity COVID-19 Program 14.218 Community Development Block Grants/Entitlement Grants U.S. Department of Housing and Urban Development Los Angeles County Development Authority No 14.871 Section 8 Housing Choice Vouchers U.S. Department of Housing and Urban Development N/A No 20.507 Federal Transit Capital and Operating Assistance Formula Grants U.S. Department of Transportation N/A No 20.600 State and Community Highway Safety U.S. Department of Transportation State of California Office of Traffic Safety No 14.896 Family Self-Sufficiency Program U.S. Department of Housing and Urban Development N/A No 20.205 Highway Planning and Construction U.S. Department of Transportation N/A No 20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated U.S. Department of Transportation State of California Office of Traffic Safety No 21.027 Coronavirus State and Local Fiscal Recovery Funds U.S. Department of Treasury California Department of Housing and Community Development Yes 97.044 Assistance to Firefighters Grant U.S. Department of Homeland Security N/A No 97.067 Homeland Security Grant Program U.S. Department of Homeland Security City of Los Angeles No 97.039 Hazard Mitigation Grant Program U.S. Department of Homeland Security California Governor’s Office of Emergency Services No 97.083 Staffing for Adequate Fire and Emergency Response U.S. Department of Homeland Security County of Los Angeles No 16.922 Equitable Sharing Program U.S. Department of Justice N/A No 16.607 Bulletproof Vest Partnership Program U.S. Department of Justice California Bureau of Justice Assistance No Sometimes the need for timeliness has to be balanced against the need for reliability, which also was identified as one of the characteristics of information in financial reporting identified in GASB Concepts Statement No. 1. While governments certainly should not sacrifice reliability for timeliness, minor gains in precision ought not to be purchased at the price of indefinite delay (e.g., accounting estimates). Legislative deadlines for submitting financial statements should be viewed as a minimum standard rather than as an ideal objective. The same holds true for the submission deadlines used by various award programs such as the Government Finance Officers Association's (GFOA) Certificate of Achievement for Excellence in Financial Reporting Program. The additional cost of more timely financial reporting (e.g., additional staff and overtime) also needs to be considered. Condition: While conducting our audit, we noted that the City experienced difficulties and delays in accurately preparing the City’s financial statements. Additionally, the City’s financial statements were not ready to be issued by the required Single Audit Reporting Package deadline of March 31, 2025. As a result of these conditions, the financial statements were not available to meet the needs of decisions makers, including governing boards, bondholders, Federal and State oversight agencies, and constituents in a timely manner. Effect or Potential Effect of Condition: Untimely financial statement reporting can alter the value of those financial statements to the users, as well as jeopardize relationships with bondholders, and granting agencies. Recommendation: Management should establish a well-defined process for its annual financial reporting. The process and its key attributes (e.g., overall timing, methodology, communication with component units, segregation of duties, frequency of analyses and review by City management) should be formally documented, approved, and reviewed on a regular basis. In addition, the City should develop more resources capable of assisting in the preparation of its annual financial reporting package. Management’s Response and Corrective Action: The City understands the importance of timeliness in financial reporting and strives to not only meet but to exceed minimum standards for reporting. This year the City was challenged by the onboarding a new audit firm, the retirement of the City’s long-time Assistant Chief Financial Officer and personnel shortages. These challenges were exacerbated by the federally declared disaster that occurred in Los Angeles County in January 2025. The City of Culver City is located within Los Angeles County and most City staff live within Los Angeles County. On January 7, 2025, multiple wildfires erupted throughout the County. The Eaton and Palisades Fires ultimately burned for several weeks, displaced hundreds of thousands of Los Angeles County residents and destroyed thousands of homes. Many City staff members were directly impacted by the fires. Many staff members were evacuated from their homes for extended periods of time, including key members of the Finance Team directly involved in the audit process. In addition, several of the City’s management staff members lost their homes, including the City’s Director of Housing and Human Services whose department oversees the City’s Section 8 Voucher Program, the focus of the single audit. The City could have addressed many of its internal challenges but for the fires. This unprecedented natural disaster significantly impacted the City’s ability to complete its financial reporting in a timely manner. The City is committed to securing additional resources and establishing a more formal process for its annual financial reporting.
Name of Contact Person: Elizabeth Shavelson, Assistant Chief Financial Officer Corrective Action: The City has established a timeline and identified milestones for its audit and financial reporting process for the Fiscal Year Ended June 30, 2025. The City will initiate the process much earlier to allow more time for completion and will continue to track and monitor is progress against its established milestones throughout the process. Along with filling vacant staff positions, the City has engaged a consultant to assist the Finance Department in developing and enhancing documentation specific to financial reporting procedures. The City has also been working with its financial software support team to streamline certain ERP system configurations in order to improve the City’s financial reporting process. Proposed Completion Date: 12/31/2025
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 26, 2022. 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 March 26, 2023, which was (1242 days ago).
What is a management decision? →Finding No. SA 2021-001 ? Schedule of Expenditures of Federal Awards (SEFA) Criteria: The following sections of the Uniform Guidance provide the following requirements: Section ?200.510 (b) Schedule of expenditures of Federal Awards; The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with ?200.502 - Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amounts of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: ? List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. ? Provide total Federal awards expended for each individual Federal program and the Assistance Listings number or other identifying number when the Assistance Listings information is not available. For a cluster of programs, also provide the total for the cluster. Section 200.303: The non-federal entity should 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. Section 200.1 defines internal control for non-Federal entities as the processes designed and implemented by non-Federal entity to provide reasonable assurance regarding the achievement of the objectives in the following categories: (i) Effectiveness and efficiency of operations; (ii) Reliability of reporting for internal and external use Condition During the course of our audit, the SEFA submitted by the City was revised a number of times as it contained errors over the assistance listing numbers (ALN), program classification, program name, awarding or pass-through agencies, as well as expenditure amounts. The following errors were noted during the audit and were referred to the City for correction. ? The payment received from the State for the Coronavirus State Fiscal Recovery Fund was reported in the preliminary SEFA. The initial amount was $4.0M then it was later changed to $45,306 which represents actual expenditures reported for FY 21. Based on the initial amount, it was determined as a major program, and as such, initial audit procedures were performed. ? The Coronavirus Relief Fund received from the State was initially reported under ALN 97.036. Upon audit inquiry, it was corrected to ALN 21.019. ? Some passthrough programs had incorrect names of awarding agency. ? In addition, the federal expenditures under the Coronavirus Relief Fund were erroneously reported in the SEFA for the fiscal year ended June 30, 2020, instead of the fiscal year ended June 30 2021. Cause There were a lot of coronavirus-related grants that were released to local governments directly from the Treasury Department and/or passed through other federal agency and the State of California during the Fiscal Year 2021. These are all new funding sources and the lack of proper guidance created confusion not just for the City but for many recipients of the funds. This resulted in the City?s financial reporting and SEFA preparation and review process not being able to accurately capture and report the grants information in the SEFA. Effect An inaccurate SEFA results in an inefficient audit approach and also increases the risk that programs may be incorrectly assessed as non-major programs. This may also lead to noncompliance with federal requirements. Questioned Costs None Recommendation We recommend that the City establish a control procedure that will ensure accurate reporting of all federal expenditures in the SEFA. The City should ensure that a process is in place for all City Departments to report and communicate to Finance Department all federal grants received by the City. The City should require all City Departments to provide the Finance Department with a copy of all approved grant agreements prior to incurring the expenses. The finance department should assign accounting personnel responsible for grant reporting and reconciliation of grant expenditures with reports submitted to the grantors and the SEFA as well as compliance with grant contract provisions and requirements. Views of Responsible Personnel As stated by the auditors, Culver City received different coronavirus relief grants that were released through a variety of different agencies (the Treasury and other federal and State agencies) in 2021. Many agencies released the funds before the final guidance on the use of the funds was approved and made available to cities. A prime example of this is the State and Local Fiscal Recovery Funds (SLFRF) under the American Rescue Plan Act. President Biden signed the Act in March 2021, and the Treasury published the Interim Final Rule in May 2021. The Final Rule providing guidance on the use of the funds was not published until January 2022 and took effect on April 1, 2022. The City received the first tranche of the SLFRF in Fiscal Year 2020-2021. The City selected the revenue replacement category for the use of the funds. Since $4.7 million was received in the FY 2020-2021, staff initially thought they had to account for the expenditures in the same fiscal year. Staff reached out to the auditors to clarify the timing necessary for the expenditures. After those discussions, it was clear that the expenditures could be accounted for in the following fiscal year. The revised amount of $45,306 presented to the auditors includes COVID-related costs incurred from March 3, 2021, the eligibility date of the funds, through June 30, 2021. The remaining expenditures for the first tranche of SLFRF in the amount of $4,641,636 will be accounted for in Fiscal Year 2021-2022. There was similar confusion surrounding the reporting of coronavirus Provider Relief Funds (PRF). The City received and fully spent the PRF of $41,614 in FY2019-2020, and reported these on the 2020 Single Audit as directed by the City?s auditor at that time. However, the Office of Inspector General of the Department of Housing and Human Services (HHS) issued an announcement in late December 2020 that cities should report the PRF on the 2021 Single Audit. The City did not receive this announcement from HHS until May 2022. The City reached out to HHS directly and was told that considering the immaterial amount of this fund, the City could report it again on the 2021 Single Audit. The City now has greater clarity on the varied coronavirus relief funds and the different requirements of the many granting agencies. Many of the questions that plagued jurisdictions early in the pandemic have been answered. The City does have a process in place that requires all City Departments to submit approved and executed grant agreements to the Finance Department before any expenses can be incurred. City Council Policy Number 5002 on Financial Policies dated June 23, 2014 addresses grant administration in Section XI. Accounting and Investment Manager, Iris Kym, will make sure that accounting personnel has access to the most current guidance from the granting agencies as they reconcile expenditures in the reports submitted to grantors and the SEFA. Assistant Chief Financial Officer, May Noller, Chief Financial Officer, Lisa Soghor, will review this work as necessary. This corrective action will be fully in place by October 1, 2022.
CITY OF CULVER CITY CORRECTIVE ACTION PLAN Year Ended June 30, 2021 Finding No. SA 2021-001 ? Schedule of Expenditures of Federal Awards (SEFA) Criteria: The following sections of the Uniform Guidance provide the following requirements: Section ?200.510 (b) Schedule of expenditures of Federal Awards; The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with ?200.502 - Basis for determining Federal awards expended. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple Federal award years, the auditee may list the amounts of Federal awards expended for each Federal award year separately. At a minimum, the schedule must: ? List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. ? Provide total Federal awards expended for each individual Federal program and the Assistance Listings number or other identifying number when the Assistance Listings information is not available. For a cluster of programs, also provide the total for the cluster. Section 200.303: The non-federal entity should 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. Section 200.1 defines internal control for non-Federal entities as the processes designed and implemented by non-Federal entity to provide reasonable assurance regarding the achievement of the objectives in the following categories: (i) Effectiveness and efficiency of operations; (ii) Reliability of reporting for internal and external use Condition During the course of our audit, the SEFA submitted by the City was revised a number of times as it contained errors over the assistance listing numbers (ALN), program classification, program name, awarding or pass-through agencies, as well as expenditure amounts. The following errors were noted during the audit and were referred to the City for correction. ? The payment received from the State for the Coronavirus State Fiscal Recovery Fund was reported in the preliminary SEFA. The initial amount was $4.0M then it was later changed to $45,306 which represents actual expenditures reported for FY 21. Based on the initial amount, it was determined as a major program, and as such, initial audit procedures were performed. ? The Coronavirus Relief Fund received from the State was initially reported under ALN 97.036. Upon audit inquiry, it was corrected to ALN 21.019. ? Some passthrough programs had incorrect names of awarding agency. ? In addition, the federal expenditures under the Coronavirus Relief Fund were erroneously reported in the SEFA for the fiscal year ended June 30, 2020, instead of the fiscal year ended June 30 2021. Cause There were a lot of coronavirus-related grants that were released to local governments directly from the Treasury Department and/or passed through other federal agency and the State of California during the Fiscal Year 2021. These are all new funding sources and the lack of proper guidance created confusion not just for the City but for many recipients of the funds. This resulted in the City?s financial reporting and SEFA preparation and review process not being able to accurately capture and report the grants information in the SEFA. Effect An inaccurate SEFA results in an inefficient audit approach and also increases the risk that programs may be incorrectly assessed as non-major programs. This may also lead to noncompliance with federal requirements. Questioned Costs None Recommendation We recommend that the City establish a control procedure that will ensure accurate reporting of all federal expenditures in the SEFA. The City should ensure that a process is in place for all City Departments to report and communicate to Finance Department all federal grants received by the City. The City should require all City Departments to provide the Finance Department with a copy of all approved grant agreements prior to incurring the expenses. The finance department should assign accounting personnel responsible for grant reporting and reconciliation of grant expenditures with reports submitted to the grantors and the SEFA as well as compliance with grant contract provisions and requirements. Corrective Action Plan As stated by the auditors, Culver City received different coronavirus relief grants that were released through a variety of different agencies (the Treasury and other federal and State agencies) in 2021. Many agencies released the funds before the final guidance on the use of the funds was approved and made available to cities. A prime example of this is the State and Local Fiscal Recovery Funds (SLFRF) under the American Rescue Plan Act. President Biden signed the Act in March 2021, and the Treasury published the Interim Final Rule in May 2021. The Final Rule providing guidance on the use of the funds was not published until January 2022 and took effect on April 1, 2022. The City received the first tranche of the SLFRF in Fiscal Year 2020-2021. The City selected the revenue replacement category for the use of the funds. Since $4.7 million was received in the FY 2020-2021, staff initially thought they had to account for the expenditures in the same fiscal year. Staff reached out to the auditors to clarify the timing necessary for the expenditures. After those discussions, it was clear that the expenditures could be accounted for in the following fiscal year. The revised amount of $45,306 presented to the auditors includes COVID-related costs incurred from March 3, 2021, the eligibility date of the funds, through June 30, 2021. The remaining expenditures for the first tranche of SLFRF in the amount of $4,641,636 will be accounted for in Fiscal Year 2021-2022. There was similar confusion surrounding the reporting of coronavirus Provider Relief Funds (PRF). The City received and fully spent the PRF of $41,614 in FY2019-2020, and reported these on the 2020 Single Audit as directed by the City?s auditor at that time. However, the Office of Inspector General of the Department of Housing and Human Services (HHS) issued an announcement in late December 2020 that cities should report the PRF on the 2021 Single Audit. The City did not receive this announcement from HHS until May 2022. The City reached out to HHS directly and was told that considering the immaterial amount of this fund, the City could report it again on the 2021 Single Audit. The City now has greater clarity on the varied coronavirus relief funds and the different requirements of the many granting agencies. Many of the questions that plagued jurisdictions early in the pandemic have been answered. The City does have a process in place that requires all City Departments to submit approved and executed grant agreements to the Finance Department before any expenses can be incurred. City Council Policy Number 5002 on Financial Policies dated June 23, 2014 addresses grant administration in Section XI. Accounting and Investment Manager, Iris Kym, will make sure that accounting personnel has access to the most current guidance from the granting agencies as they reconcile expenditures in the reports submitted to grantors and the SEFA. Assistant Chief Financial Officer, May Noller, Chief Financial Officer, Lisa Soghor, will review this work as necessary. This corrective action will be fully in place by October 1, 2022.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 19, 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 August 19, 2020, which was (2191 days ago).
What is a management decision? →2019-003 Cash Management ? Internal Control and Compliance over Reimbursement Requests Identification of the Federal Program: Catalog of Federal Domestic Assistance (?CFDA?) Number: 20.507 CDFA Title: Federal Transit Capital and Operating Assistance Formula Grants (5307) Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Number and Award Year: CA-2017-163 ? FY 17-18 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with Title 31 Code of Federal Regulations (CFR) section 205.12(b)(5), reimbursable funding means that a federal program agency (or pass-through entity) transfers federal funds to an awardee after that awardee has already paid out the funds for federal assistance program purposes. Reimbursement requests should be supported by documentation showing that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Condition: During our audit, we noted that the City did not report Transportation Development Credits (?TDC?) for $780,745 under the Federal Share of Expenditures in the Federal Financial Reports (?FFR?) for all four quarters. In addition, the City miscalculated the TDCs in the FFR for the quarter ended December 31, 2018. The City drawdowns were in excess of the allowable amounts by $78,051. Cause: The City did not have sufficient training and knowledge over internal control and compliance over reimbursement requests and did not have timely communication with Department of Transportation regarding reporting issues. Effect or Potential Effect: Department of Transportation could withhold future reimbursement payments. Questioned Costs: $78,051. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: N/A Recommendation: We recommend the City attend Federal Transit Administration related training in order to obtain adequate and accurate information about grant requirements and communicate with Department of Transportation in a timely manner.
2019-003 Cash Management ? Internal Control and Compliance over Reimbursement Requests City?s Corrective Action Plan: Transportation staff recognizes that training is needed for the reporting and management of Transportation Development Credits being applied toward the local match of Federally funded projects and activities. Members from the Transportation Department will request and complete training from the Federal Transit Administration (FTA) by June 30, 2020. The noted mistakes have been corrected in subsequent Federal Financial Reports. Transportation staff are also cognizant of the need for better communication with our FTA representative on reporting errors and strategies to correct them. Contact person responsible for corrective action: Rolando Cruz, Chief Transportation Officer Anticipated completion date: Fiscal year ending June 30, 2020
2019-004 Reporting ? Internal Control and Compliance over Reporting Identification of the Federal Program: Catalog of Federal Domestic Assistance (?CFDA?) Number: 20.507 CDFA Title: Federal Transit Capital and Operating Assistance Formula Grants (5307) Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Number and Award Year: CA-2017-163 ? FY 17-18 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Federal Financial Report (?FFR?) Instructions: 1) The submission of interim FFRs will be on a quarterly, semi-annual, or annual basis, as directed by the Federal Agency. The following reporting period end dates shall be used for interim reports: 3/31, 6/30, 9/30, or 12/31. 2) Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of each reporting period. Condition: During our audit, we noted that one of the four quarterly FFRs selected for testing was submitted after the due date. The FFR for the quarter ended December 31, 2018 was due on January 30, 2019 but was not submitted the State of California Department of Transportation until January 31, 2019. During our audit, we noted that the person in Transportation Development can prepare reimbursement requests as well as perform drawdowns of federal funds. Cause: The City did not have adequate policies and procedures to ensure the timely submission of the Federal Transaction Reports. Effect or Potential Effect: The delay in submission of the Federal Transaction Report may lead to the State of California Department of Transportation imposing sanctions on the City including withholding reimbursement payments. Questioned Costs: No questioned costs were noted. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: N/A Recommendation: We recommend the City update procedures to improve control activities over the timely submission of the reports. We also recommend the City request extensions from grantors in the future in the event that the City is unable to meet the reporting due date. We also recommend that the City improve segregation of duties within the Transportation Department.
2019-004 Reporting ? Internal Control and Compliance over Reporting City?s Corrective Action Plan: With the exception of this instance, Culver City has been very timely with all submissions of Federal Financial Reports and Milestone Progress Reports prior to their deadline. However, this submission was delayed until late in the evening on January 30, 2019 Pacific Standard Time. It was reflected as January 31, 2019 in the FTA Transit Award Management System due to the time difference. Culver City is updating its internal control policies and procedures for grants management. Going forward, Transportation staff will prepare and submit reports earlier in the month due to avoid any possibility of late submission in the future. Staff changes in the Transportation Department?s Finance area will also allow a separation of duties between the person preparing reimbursement requests and the person performing drawdowns of federal funds. Contact person responsible for corrective action: Rolando Cruz, Chief Transportation Officer Anticipated completion date: Fiscal year ending June 30, 2020
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2019, which was (2514 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 27, 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 September 27, 2018, which was (2883 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
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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