EIN: 956005780
UEI: NL6BDNFT6JE6
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 25, 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 25, 2025 (330 days ago).
What is a management decision? →We noted that the City did not meet the requirements of level of effort based on the documents provided. Cause: There was turnover of the Project Director position and there is lack of transition and training on the program requirements. Effect or Potential Effect: Not meeting the requirements of level of effort lead to the U.S. Department of Education imposing sanctions on the City including withholding future apportionments. Questioned Costs: No questioned costs were reported. Context: See condition above for context of the finding. Identification as A Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City implement policies and procedures relating training and transition of program responsibilities in event of turnover to avoid not meeting program requirements. We also recommended the City develop a process and start tracking the time and effort of the new Project Director to ensure compliance with level of effort requirement. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.
Show full finding ▾Hide full finding ▴Internal Control and Compliance over Level of Effort Identification of the Federal Program: Assistance Listing Number: 84.116z Assistance Listing Title: Fund for the Improvement of Postsecondary Education Federal Agency: Department of the Education Pass-Through Entity: None Federal Award Number and Award Year: P116Z220212 and 2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Grant Award Notification Section 5 – Key Personnel, the City is required to maintain level of effort of 10% devoting to the project by the Project Director. Condition: We noted that the City did not meet the requirements of level of effort based on the documents provided. Cause: There was turnover of the Project Director position and there is lack of transition and training on the program requirements. Effect or Potential Effect: Not meeting the requirements of level of effort lead to the U.S. Department of Education imposing sanctions on the City including withholding future apportionments. Questioned Costs: No questioned costs were reported. Context: See condition above for context of the finding. Identification as A Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City implement policies and procedures relating training and transition of program responsibilities in event of turnover to avoid not meeting program requirements. We also recommended the City develop a process and start tracking the time and effort of the new Project Director to ensure compliance with level of effort requirement. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.
The City concurs with the auditor's recommendation and will modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. The City has never had a finding in its Single Audit concerning the Level of Effort requirement. The Finance Department has drafted a Grant policy that is under review and will be approved administratively by City Manager John Moreno. The Policy instructs City staff members on the grant provisions for grant identification, grant funding analysis, administrative compliance, subrecipient monitoring, documentation, and restrictions. Upon approval, Financial Services Manager Anthony Martinez will inform and train all City staff members involved in the procurement and management of all grants. Within the components of training, City staff members will learn the requirements of the "Level of Effort" in the context of federal grants. Moreover, City staff members will learn how to satisfy and dedicate the Grant Project Manager's total work time toward the grant project while maintaining accurate documentation. In addition, Financial Services Manager Anthony Martinez will train staff in the succession of managing the responsibilities of grants to ensure all obligations are maintained during staff transitions. The Grant policy and internal training is part of a larger effort by the Finance Department to implement an administrative Fiscal Policy Manual and Fiscal Practices Training Group expected by June 30, 2025.
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
The following required procurement standards were not addressed in the City's policy: ? Conflict of interest, including disciplinary actions for failure to adhere (2 CFR 200.318) ? Avoid acquisition of duplicative items (2 CFR 200.318) ? Cost effective purchasing (2 CFR 200.318) ? Document retention (2 CFR 200.318) ? Provisions to ensure all solicitations (2 CFR 200.319): Incorporate clear and accurate descriptions of technical requirements, do not restrict competition, and identify all requirements which the offerors must fulfill and factors used in evaluation ? Disadvantaged Business Enterprise program (2 CFR 200.321) ? Recovered materials, if subject to EPA requirements (2 CFR 200.322) ? Contract price/types (2 CFR 200.323) ? Bonding requirements (2 CFR 200.325) ? Contract provisions (2 CFR 200.326) Additionally, we identified 3 instances in which the City did not verify the vendor was not suspended, debarred, or otherwise excluded before entering into a covered transaction rather, verification was performed after entering into the transaction. The City asserted that they verified the vendors were not suspended or debarred; however, no documentation of the procedure being performed prior to entering into the transaction was presented. Cause: The City?s did not ensure it?s written procedures identified all of the required federal procurement standards. Additionally, the City?s controls did not ensure the check for suspension and debarment was performed and documented prior to entering into covered transactions. Effect: The City?s documented procurement procedures do not conform to the procurement standards identified in 2 CFR sections 200. 318, 200.319, and 200.321 through 200.326. Additionally, the City did not comply with the requirements of 2 CFR 200.214. Questioned Costs: None reported. Context/Sampling: The condition noted above was identified during our procedures related to procurement, suspension, and debarment. A non-statistical sample of 4 expenditures out of a population of 12 vendors were selected for testing as a whole. Repeat Finding from Prior Year: No. Recommendation: We recommend the City modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of the Treasury Federal Financial Assistance Listing: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance, Instance of Non-compliance Criteria: General procurement standards 2 CFR 200.318 require the non-Federal entity to use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and standards identified in this part. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in 2 CFR sections 200.317 through 200.326. 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 2 CFR section 200.214. Condition: The following required procurement standards were not addressed in the City's policy: ? Conflict of interest, including disciplinary actions for failure to adhere (2 CFR 200.318) ? Avoid acquisition of duplicative items (2 CFR 200.318) ? Cost effective purchasing (2 CFR 200.318) ? Document retention (2 CFR 200.318) ? Provisions to ensure all solicitations (2 CFR 200.319): Incorporate clear and accurate descriptions of technical requirements, do not restrict competition, and identify all requirements which the offerors must fulfill and factors used in evaluation ? Disadvantaged Business Enterprise program (2 CFR 200.321) ? Recovered materials, if subject to EPA requirements (2 CFR 200.322) ? Contract price/types (2 CFR 200.323) ? Bonding requirements (2 CFR 200.325) ? Contract provisions (2 CFR 200.326) Additionally, we identified 3 instances in which the City did not verify the vendor was not suspended, debarred, or otherwise excluded before entering into a covered transaction rather, verification was performed after entering into the transaction. The City asserted that they verified the vendors were not suspended or debarred; however, no documentation of the procedure being performed prior to entering into the transaction was presented. Cause: The City?s did not ensure it?s written procedures identified all of the required federal procurement standards. Additionally, the City?s controls did not ensure the check for suspension and debarment was performed and documented prior to entering into covered transactions. Effect: The City?s documented procurement procedures do not conform to the procurement standards identified in 2 CFR sections 200. 318, 200.319, and 200.321 through 200.326. Additionally, the City did not comply with the requirements of 2 CFR 200.214. Questioned Costs: None reported. Context/Sampling: The condition noted above was identified during our procedures related to procurement, suspension, and debarment. A non-statistical sample of 4 expenditures out of a population of 12 vendors were selected for testing as a whole. Repeat Finding from Prior Year: No. Recommendation: We recommend the City modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
FINDING 2022-001 Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: United States Department of the Treasury Passed-through: N/A Compliance Requirements: Procurement, Suspension and Debarment Auditor Recommendation: We recommend the City modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. Views of Management/Responsible Officials and Corrective Action: The City concurs with the auditor?s recommendation and will modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. The City has never had a finding in its Single Audit before and was not aware that the procurement standards identified in Title 2 of the Code of Federal Regulations (CFR), specifically 2 CFR sections 200.317 through 200.326, had to be included in the City?s procurement policy. Being that this was the first time the City received the ARPA funding and was subject to this requirement, this deficiency came up. The City will review and bring its current policy up to date. The City also made an effort to comply when a deficiency was known. In August 2022, the City established its Debarment and Suspension policy. With this policy in place, the City will review its current process to ensure that going forward, verifications for debarment and suspension are performed for contractors prior to entering into transactions with them. Name of Responsible Person: Kim Sao, Finance Director Implementation Date: 6/30/2023
We identified 4 instances in which the City did not retain evidence to document the individual approving the City?s required performance reports. Current obligations were reported inaccurately for the Quarter 1 and 2 Project and Expenditure Reports. Additionally, expenditure information was reported inaccurately for the Quarter 2 Project and Expenditure Report and the report was submitted past the required deadline. Further, $48,834 for the purchase of energy efficient lighting upgrades to City Hall were reported incorrectly under ?Public Health - Negative Economic Impact? instead of ?Revenue Replacement?. Cause: The City?s procedures did not include documentation to evidence the individual that approved the reports. The City?s procedures did not ensure the Quarter 2 Project and Expenditure Report was prepared in accordance with program requirements and on a timely basis. Effect: The City did not comply with the requirements of 2 CFR 200.303 and inaccurate information was reported to the federal awarding agency. Questioned Costs: None reported. Context/Sampling: The entire population of one Interim Report and three quarterly Project and Expenditure Reports submitted during the year were selected for testing. Repeat Finding from Prior Year: No. Recommendation: We recommend the City enhance internal controls to ensure Interim and Project and Expenditure Reports are prepared in accordance with program requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of the Treasury Federal Financial Assistance Listing: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Reporting Type of Finding: Significant Deficiency, Instance of Noncompliance Criteria: Per 2 CFR 200.303, the non-Federal entity must 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. This includes internal controls over maintaining records of the preparer and approver of required reports. 2 CFR 200.329(b) requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with program requirements. The City of Paramount (the City) must submit an Interim Report and quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information pertaining to both the Interim Report and the Project and Expenditure Reports includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure Critical information pertaining to the Project and Expenditure Reports specifically includes: ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Additionally, per the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Compliance and Reporting Guidance, all recipients are required to submit Project and Expenditure Reports on a timely basis as summarized in the quarterly report timelines table of the guidance. Condition: We identified 4 instances in which the City did not retain evidence to document the individual approving the City?s required performance reports. Current obligations were reported inaccurately for the Quarter 1 and 2 Project and Expenditure Reports. Additionally, expenditure information was reported inaccurately for the Quarter 2 Project and Expenditure Report and the report was submitted past the required deadline. Further, $48,834 for the purchase of energy efficient lighting upgrades to City Hall were reported incorrectly under ?Public Health - Negative Economic Impact? instead of ?Revenue Replacement?. Cause: The City?s procedures did not include documentation to evidence the individual that approved the reports. The City?s procedures did not ensure the Quarter 2 Project and Expenditure Report was prepared in accordance with program requirements and on a timely basis. Effect: The City did not comply with the requirements of 2 CFR 200.303 and inaccurate information was reported to the federal awarding agency. Questioned Costs: None reported. Context/Sampling: The entire population of one Interim Report and three quarterly Project and Expenditure Reports submitted during the year were selected for testing. Repeat Finding from Prior Year: No. Recommendation: We recommend the City enhance internal controls to ensure Interim and Project and Expenditure Reports are prepared in accordance with program requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
FINDING 2022-002 Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: United States Department of the Treasury Passed-through: N/A Compliance Requirements: Reporting Auditor Recommendation: We recommend the City enhance internal controls to ensure Interim and Project and Expenditure Reports are prepared in accordance with program requirements. Views of Responsible Officials and Corrective Action: We concur with the recommendation and will enhance internal controls to ensure that the Interim and Project and Expenditure Reports are prepared in accordance with program requirements. During this reporting period, there was no clear direction from the State on how to submit prior period corrections, so to achieve this action, City staff submitted a zero ?current expenditure? and then included the prior period adjustment in the cumulative total. Since the audit found that this was the wrong process and a deficiency in reporting, the City will reach out to the State for assistance in reporting prior period corrections. The City will ensure a thorough review prior to submitting to ensure the report is accurate. The City also encountered reporting difficulties for the quarter ending 6/30/2022 with entering vendor information. City staff contacted the State to request assistance, however the State was overwhelmed with requests from agencies state-wide and was not able to respond to the City?s request in a timely manner. The State was aware of the issues and had allowed Cities to submit their report late. The City has not had any issue subsequent to the 6/30/2022 report and has been submitting its report timely. Name of Responsible Person: Kim Sao, Finance Director Implementation Date: 6/30/2023
FAC accepted this audit on March 29, 2017 — management decision was due September 29, 2017.
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