EIN: 956000812
UEI: GMTFPTDD6HT5
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 24, 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 September 24, 2025, which was (331 days ago).
What is a management decision? →Program/Cluster: CDBG – Entitlement/Special Purpose Grants Cluster Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award Year: 2023-24 Grant Award Number: B-23-MC-06-0533 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance, Instance of Non-Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: As a result of our audit procedures, we noted that one (1) out of one (1) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $40,000. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 - 1 - - Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $40,000 - $40,000 - - Cause: The City did not have proper internal controls in place to ensure sub-award information was submitted in accordance with FFATA. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: We tested one (1) out of one (1) first tier subawards greater than $30,000 awarded during the fiscal year. Repeat Finding from Prior Year(s): No. Recommendation: We recommend the City implement policies and procedures to ensure the requirement FFATA reports are prepared and submitted to the Federal Funding Accountability and Transparency Act Subaward Reporting System in a timely manner. Views of Responsible Officials: Management agrees. See separately issued corrective action plan.
Program/Cluster: CDBG – Entitlement/Special Purpose Grants Cluster Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award Year: 2023-24 Grant Award Number: B-23-MC-06-0533 Compliance Requirement: Reporting Management’s Response: We concur. Views of Responsible Officials and Corrective Action: As stated in the condition, the City has subsequently submitted the report after the due date. The City has implemented policies and procedures to ensure timely submission to the Federal Funding Accountability and Transparent Act Subaward Reporting System (FSRS). Name of Responsible Person: Community Development Department, Werner Abrego, Senior Economic Development and Housing Analyst Projected Implementation Date: Implemented.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 29, 2023. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 29, 2023, which was (1057 days ago).
What is a management decision? →Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Passed-through: California State Water Boards Award Year: 2021 Grant Award Number: CA1910173 Compliance Requirements: Reporting Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2022 Compliance Supplement, there are three types of reporting requirements for the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program: 1. Interim Report: Provides initial overview of status and uses of funding. The interim report will include a recipient?s expenditures through July 31, 2021 by category and at the summary level. The reporting requirements vary by type of recipient, the total allocation amount, and the date which the recipient first received its allocation. 2. Project and Expenditure Report: Report on financial data, projects funded, expenditures, and contracts and subawards over $50,000, and other information. Project and Expenditure Reports are due on a regular, recurring basis after the Interim Reports. The reporting frequency and deadlines vary by type of recipient and total allocation amount. 3. Recovery Plan Performance Report: The Recovery Plan Performance Report (the ?Recovery Plan?) will provide information on the projects that large recipients are undertaking with program funding and how they plan to ensure program outcomes are achieved in an effective, efficient, and equitable manner. It will include key performance indicators identified by the recipient and some mandatory indicators identified by Treasury. The Recovery Plan will be posted on the website of the recipient as well as provided to Treasury. For the City, this report is not required. The reporting threshold is based on the total allocation expected under the SLFRF program, not the funds received by the recipient as of the time of reporting. Reporting requirements include which reports a recipient must file, the frequency at which the recipient must report, the covered period of reporting, and the report deadlines. Reporting requirements for each type and size of recipient can be found in Part 2, Section B of the Compliance and Reporting Guidance. The City is considered a Tier 2 reporting entity due to having a population below 250,000 residents and being allocated more than $10 million in SLFRF funding. As a result, the first two reporting requirements noted above (Interim Report and Project and Expenditure Report) are applicable. Condition: Of the three reports selected for testing, we noted the following: Project and Expenditure Report ? We noted the total cumulative project expenditures reported on the June 30, 2022, Project and Expenditure Report totaled $3,603,499. However, we noted the City?s cumulative expenditures reported on the June 30, 2021 and June 30, 2022 Schedule of Expenditures of Federal Awards received directly from the US Treasury totaled $1,072,313. The difference of $2,531,186 is due to the City reporting an incorrect amount of expenditures on the Project and Expenditure Report attributed to the Coronavirus State and Local Fiscal Recovery Funds program. The City has subsequently corrected the Project and Expenditure Report, beginning with the September 30, 2022 report. We obtained the September 30, 2022 report and agreed the total expenditures reported to the June 30, 2021 and June 30, 2022 Schedule of Expenditures of Federal Awards without exception. Cause: Management did not have established policies and procedures in place for the preparation and review of the quarterly reports. For the quarterly report, management did not maintain documentation supporting the actual expenditures charged to the program. Effect: The City?s periodic Project and Expenditure Report reports did not report accurate actual program expenditures for the period March 3, 2021 through June 30, 2022. Program expenditures reported were $$3,603,499; however, total actual expenditures for this period were approximately $1,072,313. Questioned Costs: None. Context/Sampling: A nonstatistical sample of three reports out of three reports were selected for testing. Repeat Finding from Prior Year(s): Yes. See 2021-005
I. FINANCIAL STATEMENT FINDINGS None Reported II. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding 2022-001 Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Passed-through: California State Water Boards Award Year: 2021 Grant Award Number: CA1910173 Compliance Requirements: Reporting Management?s Response: We concur. Views of Responsible Officials and Corrective Action: As stated in the condition, the City has subsequently corrected the Project and Expenditure Report, beginning with the September 30, 2022 report. Immediately after the issuance of the FY2021 Single Audit Report, the City shifted our SLFRF funds spending approach and elected for the Standard Allowance. The Standard Allowance allows a local government to expend up to $10 million of its SLFRF funds in the Revenue Replacement category without having to demonstrate any actual lost revenue. The quarterly SLFRF reporting to Treasury is prepared and submitted through an online portal. The report is considered as a live document as it allows the City to amend projects previously stated and/or update total cumulative expenditures as needed. Due to the timing of the issuance of prior year Single Audit Report and our election of the Standard Allowance, the City could not amend reports previously submitted to Treasury. Name of Responsible Person: Alice Hui, Director of Finance Projected Implementation Date: October 30, 2022
2021-005
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 28, 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 28, 2023, which was (1242 days ago).
What is a management decision? →Program: CDBG - Entitlement Grants Cluster CFDA No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: 2021 Grant Award Number: Various Compliance Requirements: Special Tests & Provisions ? Wage Rate Requirements Type of Finding: Significant Deficiency, Instance of Non-Compliance Criteria: Per 29 CFR Part 5, all laborers and mechanics employed by contractors or subcontractors working on construction contracts in excess of $2,000, financed by Federal assistance funds, must be paid wages not less than those established for the locality of the project (prevailing wage rates) by DOL. 29 CFR sections 5.5 and 5.6 require the contractor or subcontractor submit weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). The Wage Rate Requirements apply to the rehabilitation of residential property that contains 8 or more units. The funding agreement signed by the City to provide CDBG funding also require compliance with prevailing wages requirements. Condition: It is noted the City contracts with a consultant to act on the City's behalf to collect and review certified payroll and ensure that certified payroll reports are submitted timely by contractors and subcontractors. However, the City does not have a policy to ensure the contractor is collecting the certifying payroll reports timely. As a result of our audit procedures, we noted the certified payroll reports for 1 out of 1 contract tested did not have evidence they were reviewed by the City to ensure they are prepared properly and submitted timely. Cause: The condition is caused by the City not having policies and procedures in place to comply with the wage rate requirements. Effect: Contractors and subcontractors may not submit certified payroll properly or timely thus increasing the risk of City?s noncompliance with the special test and provision wage rate requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of 1 out of 1 construction contract was selected for certified payroll report testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that City implement policies and procedures to document the review of certified payroll reports submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Views of Responsible Officials and Planned Corrective Actions: See separate corrective action plan. The Public Works Department along with Parks, Recreation & Community Services Department have implemented policies and procedures to document the review of certified payrolls submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely.
Program: CDBG - Entitlement Grants Cluster CFDA No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: 2021 Grant Award Number: Various Compliance Requirements: Special Tests & Provisions ? Wage Rate Requirements Management?s Response: We concur. Views of Responsible Officials and Corrective Action: The Public Works Department along with Parks, Recreation & Community Services Department have implemented policies and procedures to document the review of certified payrolls submitted by contractors and subcontractors to ensure they are prepared properly and submitted timely. Name of Responsible Person: Public Works Department Parks, Recreation & Community Services Department Projected Implementation Date: Implemented
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.430(i), Standards for Documentation of Personnel Expenses, states that charges to Federal awards for salaries and wages records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Recipients may use Coronavirus State and Local Fiscal Recovery Funds payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. ? 802 and 42 U.S.C. ? 803 respectively), Treasury?s Interim Final Rule at 31 C.F.R. ?? 35.7 and 35.8, and FAQs. Recipients may use payments from the Fund to: ? Support public health expenditures, by funding COVID-19 mitigation efforts, medical expenses, behavioral healthcare, and certain public health and safety staff; ? Address negative economic impacts caused by the public health emergency, including economic harms to workers, households, small businesses, impacted industries, and the public sector; ? Replace lost public sector revenue to provide government services; recipients may use this funding to provide government services to the extent of the reduction in revenue experienced due to the pandemic. ? Provide premium pay for essential workers, offering additional support to those who have borne and will bear the greatest health risks because of their service in critical infrastructure sectors; and ? Invest in water, sewer, and broadband infrastructure, making necessary investments to improve access to clean drinking water, support vital wastewater and stormwater infrastructure, and to expand access to broadband internet. Condition: During our testing of the City?s compliance with the Activities Allowed or Unallowed, & Allowable Costs/Costs Principles compliance requirements, we noted the following: ? 4 out of 31 non-payroll program expenditures selected for testwork, totaling $472,475, were paid to one subrecipient. We noted the funding source and compliance requirements identified in the contract with the subrecipient was related to a different federal program and not the Coronavirus State and Local Fiscal Recovery Funds program. While the expenditures appear to be an allowable activity of the program, the contract for services did not directly specify or authorize the use of Coronavirus State and Local Fiscal Recovery Funds. ? 32 out of 32 program payroll expenditures selected for testwork did not have adequate documentation to support how the payroll expenditures were attributed to the restrictions set forth in sections 602 and 603 of the Social Security Act. The payroll costs charged to the program were attributed to an after-school program. However, the City was unable to provide documentation to support that the participants in the program were eligible or were classified as a population presumed disproportionately impacted by the pandemic. Cause: The City?s policies and procedures did not ensure the use of Coronavirus State and Local Fiscal Recovery Funds was properly documented and in compliance with the program requirements. This was caused by the City using Coronavirus State and Local Fiscal Recovery Funds for expenses incurred prior to the City Council approving the use of the funds. After the City Council approved the use of the funds, the City reallocated general fund or other federal expenses to the Coronavirus State and Local Fiscal Recovery Fund. In one instance noted above, we noted the funding source and compliance requirements identified in the contract with the subrecipient was related to a different federal program and not the Coronavirus State and Local Fiscal Recovery Funds program. The City did not prepare or provide a modification to the subaward identifying Coronavirus State and Local Fiscal Recovery Funds as the federal funding source. Thus, this is deemed an unallowable cost. Effect: Lack of policies and procedures did not ensure the use of Coronavirus State and Local Fiscal Recovery Funds was properly documented. Questioned Costs: $497,396 (known questioned costs based on sample items tested). Context/Sampling: A nonstatistical sample of 63 out of 356 payroll and non-payroll expenditures were selected totaling $593,216 out of $772,313 of federal program expenditures. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the City implement policies and procedures to ensure that all program related payroll and non-payroll expenditures charged to program are documented and are attributed to the public health emergency. View of responsible officials and planned corrective actions: See separate corrective action plan. With the final rule and final SLFRF compliance and reporting guidance now in place, the City has implemented policies and procedures to ensure all program related payroll and non-payroll expenditures charged to program are documented and are attributed to the public health emergency.
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Management?s Response: We concur. Views of Responsible Officials and Corrective Action: With the final rule and final SLFRF compliance and reporting guidance now in place, the City has implemented policies and procedures to ensure all program related payroll and non-payroll expenditures charged to program are documented and are attributed to the public health emergency. Name of Responsible Person: Alice Hui, Director of Finance Projected Implementation Date: Implemented
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Per the 2021 Compliance Supplement, recipients may use award funds to enter into contracts to procure goods and services necessary to implement one or more of the eligible purposes outlined in sections 602(c) and 603(c) of the Act and Treasury?s Interim Final Rule. As such, recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. All other entities under the program, including subrecipients of a State, must follow the procurement standards in 2 CFR section 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. 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: As a result of our audit procedures, we noted the following: ? 3 out of 20 transactions tested did not have documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, the basis for the contract price, provide for full and open competition, price analysis, rationale to limit competition in those cases where competition was limited, and did not includes the applicable provisions required by Appendix II to 2 CFR Part 200. ? 3 out of 20 transactions tested did not have evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Failure to document the procurement method results in noncompliance with 2 CFR section 200.300. Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: $600,286 (known questioned costs based on sample items tested). Context/Sampling: A nonstatistical sample of 20 out of 28 contracts were selected totaling $626,055 out of $772,313 of federal program expenditures. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the City implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the City is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. View of responsible officials and planned corrective actions: See separate corrective action plan. The City has enhanced its policies and procedures to ensure procurement methods and verification of non-suspension and debarment of potential vendors are properly documented.
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Procurement and Suspension and Debarment Management?s Response: We concur. Views of Responsible Officials and Corrective Action: The City has enhanced its policies and procedures to ensure procurement methods and verification of nonsuspension and debarment of potential vendors are properly documented. Name of Responsible Person: Alice Hui, Director of Finance Projected Implementation Date: Implemented
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: Sections 602 and 603 of the Social Security Act (the ?Act?), as added by section 9901 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (Mar. 11, 2021) authorized the Coronavirus State Fiscal Recovery Fund (CSFRF) and Coronavirus Local Fiscal Recovery Fund (CLFRF) respectively (referred to collectively as the Coronavirus State and Local Fiscal Recovery Funds). The purpose of the SLFR fund is to provide direct payments to state, territorial, tribal, and certain eligible local governments to: 1. Respond to the public health emergency, COVID-19 or its negative economic impacts, including providing assistance to households, small businesses, nonprofits, and impacted industries, such as tourism, travel, and hospitality. 2. Respond to workers performing essential work during the COVID-19 public health emergency by providing premium pay to eligible workers of eligible employers that have eligible workers who are performing essential work, or by providing grants to eligible entities who perform essential work. 3. Provide government services, to the extent COVID-19 caused a reduction in revenues collected in the most recent full fiscal year of the State, Territory, Tribal government, Metropolitan city, County, or Non-entitlement units of local government. 4. Make necessary investments in water, sewer, or broadband infrastructure. In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(a) - Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information at 2 CFR 200.332(a)(1) through (6) at the time of the subaward and if any of those data elements change, include the changes in subsequent subaward modification. ? 2 CFR 200.332(d)- 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 the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: Of the one subaward tested, we noted the City did not identify all of the required elements of the subaward in accordance with 2 CFR 200.331(a). We noted the funding source and compliance requirement identified in the contract with the subrecipient was related to a different federal program and not the Coronavirus State and Local Fiscal Recovery Funds program. Additionally, we noted the City did not document a risk assessment for the one subrecipient or ensure the subrecipient is audited as required by Subpart F ? Audit Requirements. Cause: While aware of the requirements, the City did not amend or modify the subaward to identify Coronavirus State and Local Fiscal Recovery Funds as the federal funding source. The City also did not implement policies and procedures to ensure the subrecipient was monitored in accordance with 2 CFR 200.332. Effect: Failure to provide all the required subaward information and perform subrecipient monitoring results in noncompliance with 2 CFR 200.331. Questioned Costs: $472,475 (known questioned costs based on sample items tested). Context/ Sampling: A nonstatistical sample of 1 subrecipient out of 1 subrecipient was selected for testing, which accounted for $472,475 of $772,313 of federal program expenditures. The condition noted above was identified during our testing over subrecipient monitoring requirements of the program. We noted that the City entered into a subrecipient agreement with The Salvation Army (TSA) to operate a homeless transition shelter. The agreement indicated Community Development Block Grants funds would be used to reimburse TSA. However, the City did not prepare or provide a modification to the subaward identifying Coronavirus State and Local Fiscal Recovery Funds as the federal funding source. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the City prepare subaward agreements that contain all of the required elements as specified in 2 CFR 200.331(a)(1) and document the risk assessment associated with each subrecipient in accordance with 2 CFR 200.331(b). Additionally, it is recommended that the City develop monitoring procedures to verify whether the subrecipient is required to have a Single Audit, and if so, whether or not the subrecipient had one completed. We also recommend for the existing subrecipient that were not previously provided the required elements, communicate missing elements and retain documentation supporting communication. Views of Responsible Officials and Planned Corrective Actions: See separate corrective action plan. The City has prepared subaward agreements that contained all required elements as specified in 2 CFR 200.331(a)(1) and communicated the missing elements in the form of an amendment to the existing subrecipient. Additionally, the City has implemented a Subrecipient Award Risk Assessment Questionnaire as its monitoring tool to verify whether the subrecipient is required to have a Single Audit, and if so, to ensure it is completed.
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Subrecipient Monitoring Management?s Response: We concur. Views of Responsible Officials and Corrective Action: The City has prepared subaward agreements that contained all required elements as specified in 2 CFR 200.331(a)(1) and communicated the missing elements in the form of an amendment to the existing subrecipient. Additionally, the City has implemented a Subrecipient Award Risk Assessment Questionnaire as its monitoring tool to verify whether the subrecipient is required to have a Single Audit, and if so, to ensure it is completed. Name of Responsible Person: Alice Hui, Director of Finance Projected Implementation Date: Implemented
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Reporting Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2021 Compliance Supplement, there are three types of reporting requirements for the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program: 1. Interim Report: Provides initial overview of status and uses of funding. The interim report will include a recipient?s expenditures through July 31, 2021 by category and at the summary level. The reporting requirements vary by type of recipient, the total allocation amount, and the date which the recipient first received its allocation. For the City, this is a one-time report and was due on August 31, 2021. 2. Project and Expenditure Report: Report on financial data, projects funded, expenditures, and contracts and subawards over $50,000, and other information. Project and Expenditure Reports are due on a regular, recurring basis after the Interim Reports. The reporting frequency and deadlines vary by type of recipient and total allocation amount. For the City, the due date of the first quarterly report was January 31, 2022, for a period March 3, 2021 through December 31, 2021. 3. Recovery Plan Performance Report: The Recovery Plan Performance Report (the ?Recovery Plan?) will provide information on the projects that large recipients are undertaking with program funding and how they plan to ensure program outcomes are achieved in an effective, efficient, and equitable manner. It will include key performance indicators identified by the recipient and some mandatory indicators identified by Treasury. The Recovery Plan will be posted on the website of the recipient as well as provided to Treasury. For the City, this report is not required. The reporting threshold is based on the total allocation expected under the SLFRF program, not the funds received by the recipient as of the time of reporting. Reporting requirements include which reports a recipient must file, the frequency at which the recipient must report, the covered period of reporting, and the report deadlines. Reporting requirements for each type and size of recipient can be found in Part 2, Section B of the Compliance and Reporting Guidance. The City is considered a Tier 2 reporting entity due to having a population below 250,000 residents and being allocated more than $10 million in SLFRF funding. As a result, the first two reporting requirements noted above (Interim Report and Project and Expenditure Report) are applicable. Condition: Of the 2 reports selected for testing, we noted the following: 1. Interim Report ? a. We noted no evidence of management review prior to the submission of the interim report. We also noted the expenditures reported on the Interim Report did not reconcile or agree to the general ledger for the period March 3, 2021 through July 31, 2021. 2. Project and Expenditure Report ? a. We noted the project expenditures reported on the Quarterly Report did reconcile to the general ledger for the period March 3, 2021 through December 31, 2021. However, we noted the project obligations, subawards, and direct payments greater than $50,000 and below $50,000 in the aggregate reported in the quarterly report could not be reconciled to support. Cause: Management did not have established policies and procedures in place for the preparation and review of the interim and quarterly reports. For the interim report, management used estimated or budgeted expenditures and not actual expenditures. For the quarterly report, management did not maintain documentation supporting the obligations for each project. Effect: The City?s interim report did not report accurate actual program expenditures for the period March 3, 2021 through July 31, 2021. Program expenditures reported were $3,009,889, however, total actual expenditures for this period were approximately $1,100,000. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 2 reports out of 2 reports were selected for testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend the City implement formal policies and procedures of the reporting of Coronavirus State and Local Fiscal Recovery Funds. According to the Compliance and Reporting Guidance published by the US Department of the Treasury, all recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of the Guidance. Organizations should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, organizations need to establish internal controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. View of responsible officials and planned corrective actions See separate corrective action plan. With the final rule and final SLFRF compliance and reporting guidance now in place, the City has implemented policies and procedures to ensure the reporting requirements is met.
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Reporting Management?s Response: We concur. Views of Responsible Officials and Corrective Action: With the final rule and final SLFRF compliance and reporting guidance now in place, the City has implemented policies and procedures to ensure the reporting requirements is met. Name of Responsible Person: Alice Hui, Director of Finance Projected Implementation Date: Implemented
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Period of Performance Type of Finding: Instance of Non-Compliance and Material Weakness in Internal Control over Compliance Criteria: In accordance with the 2021 Compliance Supplement, recipients may only use funds to cover costs incurred during the period beginning on March 3, 2021 and ending on December 31, 2024 per section 602(g)(1) of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 and Treasury?s Interim Final Rule at 31 C.F.R. ? 35.5(a). Recipients must liquidate all obligations incurred by December 31, 2024 under the award no later than December 31, 2026, which is the end of the period of performance. In addition, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal control should include procedures to ensure appropriate period of performance. Condition: We noted 2 out of 63 expenditures selected for testwork were for services rendered before March 3, 2021 and are deemed unallowable. Cause: While aware of the requirements, the City did not have internal controls in place to ensure compliance with the period of performance requirements. Effect: The City charged expenditures to the program that were incurred prior to March 3, 2021. Thus, the expenditures are deemed unallowable. Failure to review expenditures at a detail level could result in unallowable costs or expenditures claimed outside of the award?s period of performance. Questioned Costs: $7,920 (known questioned costs based on sample items tested). Context/Sampling: A nonstatistical sample of 63 out of 356 payroll and non-payroll expenditures were selected totaling $593,216 out of $772,313 of federal program expenditures. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the City implement policies and procedures to ensure they comply with the period of performance requirements. View of responsible officials and planned corrective actions: See separate corrective action plan. With the final rule and final SLFRF compliance and reporting guidance now in place, the City has implemented policies and procedures to ensure expenditures comply with the period of performance requirements.
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirements: Period of Performance Management?s Response: We concur. Views of Responsible Officials and Corrective Action: With the final rule and final SLFRF compliance and reporting guidance now in place, the City has implemented policies and procedures to ensure expenditures comply with the period of performance requirements. Name of Responsible Person: Alice Hui, Director of Finance Projected Implementation Date: Implemented
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 20, 2021. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 20, 2021, which was (1858 days ago).
What is a management decision? →Finding 2020-001 Program: Highway Planning and Construction Cluster CFDA No.: 20.205/20.219 Federal Grantor: U.S. Department of Transportation Passed-through: State of California Department of Transportation Award No.: Various Award Year: Various Compliance Requirement: Procurement and Suspension and Debarment Criteria or Specific Requirement: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. The requirements for nonprocurement suspension and debarment are contained in OMB guidance in 2 CFR part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension;? federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR part 180; program legislation; and the terms and conditions of the award. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Excluded Party List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/ (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Found: Significant Deficiency, Instance of Non-Compliance ? Management is required to perform verification for all covered transactions by checking the Excluded Party List System (EPLS), collecting a certification, or adding a clause or condition to the covered transaction to ensure that covered transactions are not awarded to suspended or debarred parties. As a result of our testwork, we noted that management did not have adequate controls in place to ensure compliance with this requirement as there was no evidence maintained that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Questioned Costs: No questioned costs have been identified. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Repeat Finding: Not a repeat finding. Context: In our tests of 4 out of 4 vendor contracts, management could not provide evidence that the vendor was not suspended or debarred prior to the execution of the contract. Effect: Noncompliance with the requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Cause: Procedures were not in place to verify vendors were not suspended or debarred prior to the execution of the contract. Recommendation: We recommend that management implement policies to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the City is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. View of responsible officials and planned corrective actions The Public Works Department is in the process of preparing a Federal Grant Checklist. This checklist will notify staff to verify SAM registration and make sure the vendor is not suspended or debarred prior to the execution of the contract.
I. FINANCIAL STATEMENT FINDINGS None Reported II. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding 2020-001 Program: Highway Planning and Construction Cluster CFDA No.: 20.205/20.219 Federal Grantor: U.S. Department of Transportation Passed-through: State of California Department of Transportation Award No.: Various Award Year: Various Compliance Requirement: Procurement and Suspension and Debarment Management?s or Department?s Response: We concur. Views of Responsible Officials and Corrective Action: The Public Works Department is in the process of preparing a Federal Grant Checklist. This checklist will notify staff to verify SAM registration and make sure the vendor is not suspended or debarred prior to the execution of the contract. Name of Responsible Person: Cesar Rangel, Assistant Director of Public Works Projected Implementation Date: December 2020
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 22, 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 22, 2018, which was (2890 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.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and compliance status.
Start monitoring →Single Audit Intelligence is an independent tool powered by Federal Audit Clearinghouse data. Not affiliated with GSA, OMB, or any federal agency.