EIN: 956000794
UEI: J2JWJVWQ8EA6
Data as of August 21, 2026
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 (41 days from today).
What is a management decision? →Identification of the Federal Program: Assistance Listing Number: 16.922 Assistance Listing Title: Equitable Sharing Program Federal Agency: U.S. Department of the Justice Federal Award Identification Number: N/A Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Prior to entering into subawards and contracts with award funds, recipients must ensure that contractors and subcontractors are not suspended, debarred, or otherwise excluded from participation in federally funded programs pursuant to 2 CFR Part 180 and 2 CFR §200.214. Condition: During the audit, we noticed that the City did not perform suspension and debarment checks on the contractors that they hired with Asset Forfeiture monies. Cause: The City does not have formal policies and procedures in place to ensure the suspension and debarment review process over vendors that provides goods or services to the City’s programs was conducted prior to entering into a contract. Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects prior to the contract being awarded, the City could be contracting with vendors that are prohibited from working on federally funded projects and incurring potentially disallowed costs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommended the City develop policies and procedures to incorporate the suspension and debarment verification prior to awarding contracts. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.
The City will update its written procurement procedures to incorporate suspension and debarment review requirements consistent with 2 CFR Part 180 and 2 CFR §200.214. Training will be provided for staff responsible for purchasing and grant administration to ensure compliance with federal requirements. Responsible Persons: Police Chief/Finance Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27
Identification of the Federal Program: Assistance Listing Number: 16.922 Assistance Listing Title: Equitable Sharing Program Federal Agency: U.S. Department of the Justice Federal Award Identification Number: N/A Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Prior to entering into subawards and contracts with award funds, recipients must ensure that contractors and subcontractors are not suspended, debarred, or otherwise excluded from participation in federally funded programs pursuant to 2 CFR Part 180 and 2 CFR §200.214. Condition: During the audit, we noticed that the City did not perform suspension and debarment checks on the contractors that they hired with Asset Forfeiture monies. Cause: The City does not have formal policies and procedures in place to ensure the suspension and debarment review process over vendors that provides goods or services to the City’s programs was conducted prior to entering into a contract. Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects prior to the contract being awarded, the City could be contracting with vendors that are prohibited from working on federally funded projects and incurring potentially disallowed costs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommended the City develop policies and procedures to incorporate the suspension and debarment verification prior to awarding contracts. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.
The City will update its written procurement procedures to incorporate suspension and debarment review requirements consistent with 2 CFR Part 180 and 2 CFR §200.214. Training will be provided for staff responsible for purchasing and grant administration to ensure compliance with federal requirements. Responsible Persons: Police Chief/Finance Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27
Identification of the Federal Program: Assistance Listing Number: 16.922 Assistance Listing Title: Equitable Sharing Program Federal Agency: U.S. Department of the Justice Federal Award Identification Number: N/A Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per the U.S. Department of Justice Equitable Sharing Guidelines, participating agencies are required to submit an Annual Certification Report that is: - Accurate and complete, and - Supported by underlying accounting records, and - Consistent with reported expenditures and program activity The report must properly classify expenditures by category (e.g., equipment, salaries, overtime) and include all allowable uses of funds. Condition: During our review of the City’s Annual Certification Report for the Equitable Sharing Program, we noted that the U.S. Department of Justice requested the report to be revised updating overtime expenditures which were originally classified and reported under salaries (line item l) to be properly classified and reported under overtime (line item j). Additionally, the original and the revised reports submitted by the City omitted $20,000 of equipment expenditures (line item d). As a result, total expenditures were understated due to the omitted equipment costs. Cause: The discrepancy was due to an oversight during the revision process, where the City updated the classification of expenditures (salary to overtime) but did not perform a complete reconciliation of total expenditures after making the revision. As a result, while overtime was correctly reported, certain equipment expenditures were inadvertently omitted, leading to an understatement of total expenditures by approximately $20,000. Effect or Potential Effect: The omission resulted in an incomplete and inaccurate Annual Certification Report, as total expenditures reported to the Department of Justice were understated. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommend the City implement a formal reconciliation and review process for the Annual Certification Report to ensure total expenditures reconcile to the general ledger, all expenditure categories are complete and accurately reported, and any revisions are followed by a full validation of completeness and accuracy prior to resubmission. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.
The misclassification and subsequent omission of approximately $20,000 in equipment expenditures occurred during the revision of the Annual Certification Report for the Equitable Sharing Program. While correcting the classification of overtime expenditures, a full reconciliation of total expenditures to the underlying accounting records was not completed, resulting in the inadvertent omission of equipment costs. The City has reinforced existing review procedures and implemented an additional step requiring a documented reconciliation of the Annual Certification Report totals to the general ledger prior to submission and after any revisions or resubmissions. Responsible Persons: Police Chief Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27
Identification of the Federal Program: Assistance Listing Number: 16.922 Assistance Listing Title: Equitable Sharing Program Federal Agency: U.S. Department of the Justice Federal Award Identification Number: N/A Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per the U.S. Department of Justice Equitable Sharing Guidelines, participating agencies are required to submit an Annual Certification Report that is: - Accurate and complete, and - Supported by underlying accounting records, and - Consistent with reported expenditures and program activity The report must properly classify expenditures by category (e.g., equipment, salaries, overtime) and include all allowable uses of funds. Condition: During our review of the City’s Annual Certification Report for the Equitable Sharing Program, we noted that the U.S. Department of Justice requested the report to be revised updating overtime expenditures which were originally classified and reported under salaries (line item l) to be properly classified and reported under overtime (line item j). Additionally, the original and the revised reports submitted by the City omitted $20,000 of equipment expenditures (line item d). As a result, total expenditures were understated due to the omitted equipment costs. Cause: The discrepancy was due to an oversight during the revision process, where the City updated the classification of expenditures (salary to overtime) but did not perform a complete reconciliation of total expenditures after making the revision. As a result, while overtime was correctly reported, certain equipment expenditures were inadvertently omitted, leading to an understatement of total expenditures by approximately $20,000. Effect or Potential Effect: The omission resulted in an incomplete and inaccurate Annual Certification Report, as total expenditures reported to the Department of Justice were understated. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommend the City implement a formal reconciliation and review process for the Annual Certification Report to ensure total expenditures reconcile to the general ledger, all expenditure categories are complete and accurately reported, and any revisions are followed by a full validation of completeness and accuracy prior to resubmission. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.
The misclassification and subsequent omission of approximately $20,000 in equipment expenditures occurred during the revision of the Annual Certification Report for the Equitable Sharing Program. While correcting the classification of overtime expenditures, a full reconciliation of total expenditures to the underlying accounting records was not completed, resulting in the inadvertent omission of equipment costs. The City has reinforced existing review procedures and implemented an additional step requiring a documented reconciliation of the Annual Certification Report totals to the general ledger prior to submission and after any revisions or resubmissions. Responsible Persons: Police Chief Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27
Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants Cluster - Entitlement/Special Purpose Federal Agency: U.S. Department of the Housing and Urban Development Pass-through Entity: County of Orange Community Resources Department Pass-through Identification Number: J2JWJVWQBEA6 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): For federally funded programs, recipients are required to establish and maintain effective internal control over compliance in accordance with 2 CFR §200.303. These controls should provide reasonable assurance that federal awards are managed in compliance with applicable laws, regulations, and the provisions of contracts or grant agreements. Pursuant to 2 CFR §§200.403 through 200.405, costs charged to federal programs must be allowable, reasonable, necessary, and adequately documented. Recipients must maintain sufficient documentation to support the nature of expenditures, vendor selection, and cost reasonableness to ensure compliance with allowable cost principles. Additionally, in accordance with 2 CFR §§200.318 through 200.327, recipients are required to follow documented procurement procedures that reflect applicable federal standards. These standards include conducting procurements in a manner providing for full and open competition, using appropriate procurement methods, performing cost or price analysis when required, and maintaining adequate documentation to support the procurement process. Recipients are also responsible for ensuring that procurement activities performed by third parties or contractors on their behalf comply with federal requirements. Pursuant to 24 CFR §570.603 and the Davis-Bacon Act (40 U.S.C. §§3141–3148), CDBG-funded construction and rehabilitation activities exceeding applicable thresholds must comply with federal labor standards. These requirements include applying the appropriate prevailing wage rates, incorporating wage determinations into bid and contract documents, and ensuring contractor compliance through certified payrolls and proper worker classifications. Further, pursuant to 24 CFR §570.506, when CDBG funds are used for rehabilitation activities, recipients must ensure that work is completed in accordance with applicable laws, codes, and requirements related to housing safety, quality, and habitability. This includes ensuring that required permits are obtained and inspections are performed in accordance with local building and safety requirements prior to and throughout construction activities. Condition: During our audit of the CDBG program, we identified the following deficiencies related to internal control and compliance over compliance requirements: Allowable Costs/Cost Principles: The City did not maintain sufficient documentation to support compliance with federal requirements related to CDBG-funded rehabilitation activities. As a result, we were unable to determine whether the costs charged to the program complied with federal allowable cost requirements. Procurement and Suspension and Debarment: The City did not perform procurement procedures in accordance with federal requirements. There was no documentation of competitive procurement methods, cost or price analysis, or justification for noncompetitive procurement. Additionally, the City did not maintain evidence demonstrating that procurement activities performed by a consultant on its behalf complied with Uniform Guidance requirements. Special Tests and Provisions –Wage Rate: The City did not obtain or maintain documentation, such as certified payroll records, to demonstrate that contractors complied with federal prevailing wage requirements for applicable rehabilitation projects. Special Tests and Provisions – Rehabilitation: During our testing of nine CDBG-funded rehabilitation projects, we noted that one project had a building permit on file that expired in 2008 and was not renewed prior to or during construction. Additionally, five projects had building permits that were issued after construction activities had already commenced, indicating that required permits were not obtained prior to the start of rehabilitation work. Cause: The City has not established and implemented effective internal controls and monitoring procedures over its CDBG program to ensure compliance with all federal requirements. Effect or Potential Effect: The City did not maintain sufficient documentation to support expenditures, limiting its ability to demonstrate that costs charged to the program are allowable and reasonable, which may result in questioned costs. Additionally, deficiencies in procurement practices increase the risk of noncompliance with federal procurement requirements, which may result in unsupported or disallowed costs. Failure to apply and document required wage rate determinations resulted in noncompliance with federal labor standards requirements, and increased risk that contractors were not compensated in accordance with prevailing wage laws. Additionally, failure to obtain and maintain valid permits prior to construction increases the risk of noncompliance with rehabilitation requirements and may result in ineligible activities. Questioned Costs: Not determinable. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommend that the City strengthen its internal control system over the CDBG program by developing and implementing formal policies and procedures to ensure compliance with federal requirements. This includes attending HUD trainings, establishing documented procurement procedures consistent with Uniform Guidance, ensuring appropriate oversight of consultants performing procurement activities, and maintaining adequate documentation to support vendor selection and cost reasonableness. The City should also implement procedures to ensure compliance with Davis-Bacon labor standards, including obtaining and reviewing certified payroll records and maintaining supporting documentation for wage rate compliance. Additionally, the City should enhance its monitoring procedures over rehabilitation activities by maintaining sufficient documentation to support that work was performed in accordance with program requirements, including evidence of inspections and completion of approved work; permits or local approvals alone should not be relied upon as sole evidence of compliance. The City should provide training to staff involved in program administration and implement ongoing monitoring procedures to ensure compliance with federal requirements. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.
The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consistent with Uniform Guidance requirements, including cost/price analysis and justification for contractor selection, collection and review of Davis-Bacon documentation, including wage determinations and certified payrolls, when applicable, verification that required permits are obtained prior to construction and retention of inspection and completion documentation, and secondary review by City staff to ensure all required documentation is complete prior to project closeout. Additionally, the City will provide training to staff involved in CDBG program administration. Responsible Persons: Community Development Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27
Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants Cluster - Entitlement/Special Purpose Federal Agency: U.S. Department of the Housing and Urban Development Pass-through Entity: County of Orange Community Resources Department Pass-through Identification Number: J2JWJVWQBEA6 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): For federally funded programs, recipients are required to establish and maintain effective internal control over compliance in accordance with 2 CFR §200.303. These controls should provide reasonable assurance that federal awards are managed in compliance with applicable laws, regulations, and the provisions of contracts or grant agreements. Pursuant to 2 CFR §§200.403 through 200.405, costs charged to federal programs must be allowable, reasonable, necessary, and adequately documented. Recipients must maintain sufficient documentation to support the nature of expenditures, vendor selection, and cost reasonableness to ensure compliance with allowable cost principles. Additionally, pursuant to 2 CFR §200.318, non-Federal entities are required to use documented procurement procedures that reflect applicable federal, state, and local requirements. These procedures must ensure that procurement activities are conducted in a manner providing for full and open competition, use appropriate procurement methods, and include adequate documentation to support vendor selection and cost reasonableness. Recipients are responsible for ensuring that procurement activities performed by employees, consultants, or contractors on their behalf comply with these requirements. Failure to follow these procedures may result in costs that are not adequately supported as allowable under federal requirements. Further, pursuant to 24 CFR §570.506, when CDBG funds are used for rehabilitation activities, recipients must ensure that work is completed in accordance with applicable laws, codes, and requirements related to housing safety, quality, and habitability. This includes ensuring that required permits are obtained and inspections are performed in accordance with local building and safety requirements prior to and throughout construction activities. Condition: During our audit of the CDBG program, we identified the following deficiencies related to internal control and compliance over compliance requirements: Allowable Costs/Cost Principles: The City did not maintain sufficient documentation to support compliance with federal requirements related to CDBG-funded rehabilitation activities. Specifically, the City did not maintain adequate documentation to support vendor selection, cost reasonableness, or the basis for contractor procurement. In addition, the City did not maintain evidence demonstrating that procurement-related activities performed by a consultant on its behalf were conducted in accordance with established procedures. Special Tests and Provisions – Rehabilitation: During our testing of nine CDBG-funded rehabilitation projects, we noted that one project had a building permit on file that expired in 2008 and was not renewed prior to or during construction. Additionally, five projects had building permits that were issued after construction activities had already commenced, indicating that required permits were not obtained prior to the start of rehabilitation work. Cause: The City has not established and implemented effective internal controls and monitoring procedures over its CDBG program to ensure compliance with all federal requirements. Effect or Potential Effect: The City did not maintain sufficient documentation to support expenditures, limiting its ability to demonstrate that costs charged to the program are allowable, reasonable, and adequately supported in accordance with federal requirements. As a result, there is an increased risk that costs may be questioned or disallowed. Additionally, failure to obtain and maintain valid permits prior to construction increases the risk of noncompliance with rehabilitation requirements and may result in ineligible activities. Questioned Costs: None. Context: See condition above for the context of the finding. Recommendation: We recommend that the City strengthen its internal control system over the CDBG program by implementing and documenting formal policies and procedures to ensure compliance with federal requirements. This includes maintaining sufficient documentation to support vendor selection, cost reasonableness, and overall allowability of costs, as well as ensuring appropriate oversight of consultants performing activities on the City’s behalf. Additionally, the City should enhance its monitoring procedures over rehabilitation activities by maintaining sufficient documentation to support that work was performed in accordance with program requirements, including evidence of inspections and completion of approved work; permits or local approvals alone should not be relied upon as sole evidence of compliance. The City should provide training to staff involved in program administration and implement ongoing monitoring procedures to ensure compliance with federal requirements. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.
The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consistent with Uniform Guidance requirements, including cost/price analysis and justification for contractor selection, collection and review of Davis-Bacon documentation, including wage determinations and certified payrolls, when applicable, verification that required permits are obtained prior to construction and retention of inspection and completion documentation, and secondary review by City staff to ensure all required documentation is complete prior to project closeout. Additionally, the City will provide training to staff involved in CDBG program administration. Responsible Persons: Community Development Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27
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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