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FY 2019 Audit Finding Clearance from U.S. Department of Housing & Copyrighted J uly 20, 2020 City of Dubuque Consent Items # 22. City Council Meeting ITEM TITLE: FY2019 Audit Finding Clearance from U.S. Department of Housing & Urban Development SUM MARY: City Manager transmitting information regarding the U.S. Department of Housing & Urban Development (HUD)Audit Finding Clearance. SUGGESTED Suggested Disposition: Receive and File DISPOSITION: ATTACHMENTS: Description Type HUD Audit Finding Clearance-MVM Memo City Manager Memo Staff Memo Staff Memo City of Dubuque Audit Finding Clearance Letter Supporting Documentation Dubuque THE CITY OF � ui-Aseria cih DuB E , . � . , � II � Maste iece on tj2e Mississi i zoo�•zoiz•zois YP pp zoi�*zoi9 TO: The Honorable Mayor and City Council Members FROM: Michael C. Van Milligen, City Manager SUBJECT: U.S. Department of Housing & Urban Development (HUD) Audit Finding Clearance DATE: July 16, 2020 Housing and Community Development Director Alexis Steger is transmitting information regarding the U.S. Department of Housing & Urban Development (HUD) Audit Finding Clearance. The City of Dubuque Comprehensive Annual Financial Report (CAFR) and audit report were reviewed by the City Council on April 20, 2020. Noted in the audit report were findings of a material weakness in the Single Audit for the Community Development Block Grant. These findings are required to be submitted to the Federal Agency overseeing the program (HUD) with corrective actions that resolve any continuing weakness. HUD completed a due diligence follow-up to this submission to ensure the City of Dubuque's new procedures would correct the material weakness. The City of Dubuque Housing Department had taken immediate steps to correct weaknesses the auditors found, even before the official report was released. The Housing and Community Development Department contracted with the National Community Development Association to hold a training in Dubuque for CDBG. Holding the training in Dubuque allowed several City Staff to attend this training, including the City Attorney, Senior Counsel, Housing and Community Development Staff, Leisure Services Staff and the City Manager's Office Staff. Additionally, new procedures for time allocation were put into place. These procedures were reviewed by HUD and an Audit Finding Clearance Letter was issued to the City of Dubuque. This letter indicates that the City of Dubuque is ensuring weaknesses in the program are being corrected, and HUD agrees that the City remains in good standing based on these corrective actions. v Mic ael C. Van Milligen MCVM:jh Attachment cc: Crenna Brumwell, City Attorney Teri Goodmann, Assistant City Manager Cori Burbach, Assistant City Manager Alexis M. Steger, Housing & Community Development Director 2 Dubuque City of Dubuque THE CITY OF � Housing& Community All•AreerieaE�y � Development �uB E ������ ����� 7350 W. 6th Street, Suite 312 1 I EOPPORTUHS7Y 1�UUUClUe� lA SZOO I Z007«2012+2013 Masterpiece on the Mississippi 2017*2019 Office (563) 589-4230 TO: Michael C. Van Milligen, City Manager FROM: Alexis M. Steger, Housing & Community Development Director DATE: July 15, 2020 RE: U.S. Department of Housing & Urban Development (HUD) Audit Finding Clearance BACKGROUND The City of Dubuque Comprehensive Annual Financial Report (CAFR) and audit report were reviewed by the City Council on April 20, 2020. Noted in the audit report were findings of a material weakness in the Single Audit for the Community Development Block Grant. These findings are required to be submitted to the Federal Agency overseeing the program (HUD) with corrective actions that resolve any continuing weakness. HUD completed a due diligence follow-up to this submission to ensure the City of Dubuque's new procedures would correct the material weakness. DISCUSSION The City of Dubuque Housing Department had taken immediate steps to correct weaknesses that auditors found, even before the official report was released. The Housing Department contracted with the National Community Development Association to hold a training in Dubuque for CDBG. Holding the training in Dubuque allowed several City Staff to attend this training, including the City Attorney, Senior Counsel, Housing & Community Development Staff, Leisure Services Staff and the City Manager's Office Staff. Additionally, new procedures for time allocation were put into place. These procedures were reviewed by HUD and the attached Audit Finding Clearance Letter was issued to the City of Dubuque. This letter indicates that the City of Dubuque is ensuring weaknesses in the program are being corrected, and HUD agrees that the City remains in good standing based on these corrective actions. REQUESTED ACTION No action is requested by the City Council. This memorandum is for information purposes only. Cc: Jenny Larson, Finance and Budget Director Teri Goodmann, Assistant City Manager Service People Integrity Responsibility Innovation Teamwork ��e�n�Nr o.r tiaP , yo, U.S.Department of Housing and Urban Development ; ��oo�;�ll � � Omaha Field Office °� IIIIIIII n� Edward Zorinsky Federal Building Gy q� 1616 Capitol Avenue,Suite 329 g�"oE��`� Omaha, Nebraska 68102-4908 July 13, 2020 Ms. Alexis Steger Housing and Community Dev Director City of Dubuque 350 West 6th Street Suite 312 Dubuque, IA 52001 Dear Ms. Steger: Subject: 2 CFR Part 200 Audit Findings Audit for Fiscal Year ending June 30, 2019 City of Dubuque We are in receipt of your June 26, 2020 letter responding to our May 27, 2020 letter regarding one of the two findings identified in the agency's Single Audit for the fiscal year ending June 30, 2019 that relates to the Community Development Block Grant (CDBG) program (the other finding was cleared in our May 27, 20201etter). We accept your response and consider the audit closed for our purposes. 2019-002 US Department of Housing and Urban Development CDBG—Entitlement Grants Cluster CFDA# 14.218 Community Development Block Grant/Entitlement Grants Federal Award Numbers B-17-MC-19-0004, B-17-MC-19-0004, B-17-MC-19-0004, and B-17-MC-19-0004 for the fiscal year ended June 30, 2019 Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: A properly designed system of internal control over compliance with the requirements of federal programs allows entities to meet those requirements set forth by the federal government in administering federal grants. The Uniform Guidance (2 CFR 200.430) requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Records must support the distribution of the employee's salaries or wages among specific activities or cost objectives. Condition: During our testing of payroll expenditures and related time sheets, we noted that the time sheets maintained as part of the City's records did not reflect the specific activities being performed by the employee. Cause: The City's internal controls over compliance are not properly designed to capture the information required by Uniform Guidance. 2 Effect: The City did not comply with the Uniform Guidance regarding employee records. Questioned Costs: Salaries and benefits of$246,995 were included in program eXpenditures. We were unable to determine the amount of questioned costs, if any, because we were unable to determine the actual time incurred by the employees. Context/Sampling: A non-statistical sample of 60 transactions, which included 10 payroll related items were selected for testing. The 10 payroll items tested accounted for$32,000 of the$246,995 of salaries and benefits included in program expenditures. Repeat Finding from Prior Year(s): No Recommendation: We recommend the City develop, document, and retain a formal time study that complies with the requirements of the Uniform Guidance. Views of Responsible O�cials: We agree with the auditor's comments. The following action will be taken to improve the situation. The City of Dubuque is recording salary and wages based on actual activities performed in a day on timesheets, backed by outlook calendar attachments until another time study can be completed. The time study completed in FY 2019 was over 3 months and was documented by 30-minute intervals for each activity completed. Unfortunately,not every employee's documentation was placed in the permanent payroll files and was therefore unavailable for review and needs to be re-created in a new time study. Responsible Individuals: Alexis Steger, Housing and Community Development Director Anticipated Completion Date: June 30, 2020 HUD Management Decision: HUD sustains the Audit Finding. HUD Required Corrective Action: The City is advised to submit a written policy that addresses the allocation of staff wages to the CDBG program. Include samples of timesheets and descriptions of systems that are used to track staff time by activity. Also describe the training policy that includes who was trained and when they were trained. Grantee's Response: The agency submitted details concerning training completed with staff, specifically identifying who was trained and the nature of the training. Also, attached to the letter were examples of timesheets and supporting documentation for time allocated to the CDBG program. Please send us the updated Standard Operating Procedures for timekeeping when completed. 2019-003 US Department of Housing and Urban Development CDBG—Entitlement Grants Cluster CFDA# 14.218 Community Development Block Grant/Entitlement Grants Federal Award Numbers B-17-MC-19-0004, B-17-MC-19-0004, B-17-MC-19-0004, and B-17-MC-19-0004 for the fiscal year ended June 30, 2019 3 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Federal regulations require the submission of quarterly financial reports of the program. Condition: Required quarterly reports for September 30, 2018 and December 31, 2018 were not filed with the granting agency. Cause: Staff turnover resulted in a miscommunication on the responsibility for submitting the quarterly reports (SF-425). Effect.• The City did not comply with the reporting requirements. Questioned Costs: None. Context/Sampling: 2 of the 4 quarterly reports were not filed. Repeat Finding from PNior Year(s): No Recommendation: We recommend the City develop and implement procedures to ensure reports are prepared and reviewed in compliance with the reporting requirements of the grant. Views of Responsible Officials: We agree with the Auditor's comments. Officials found that HUD informs only those on the distribution list when a report is missing. This allowed a single employee to ignore the requests for quarterly reporting, without raising the awareness of anyone else in the organization that the reports were not completed. The following action will be taken to improve the situation. The City of Dubuque has mandated two employees receive notifications from HUD. Additionally, one employee is responsible for the preparation of the report, another is responsible for review and submission of the report. The Director is then responsible for the signature of approval. This ensures that three employees have responsibility and sign offto check the quarterly report has been submitted. Additionally, the Community Development Advisory Commission adopted a schedule of Federally Required Submissions, so they can monitor the status of those submissions. Employees that prepare the agenda for the Commission are not part of the submission process, and therefore are a secondary control to ensure the Commission receives documentation that required reports are filed. Commission meeting minutes from the Community Development Advisory Commission are placed on the City Council agenda far review and approval; therefore, a third control mechanism for ensuring required documentation is submitted timely. Responsible Individuals: Alexis Steger, Housing and Community Development Director Anticipated Completion Date: June 30, 2020 HUD Management Decision: HUD sustains the Audit Finding. HUD Required Corrective Action: We accept the City's corrective action as outlined in the audit. No further response is required. 4 If you have any questions regarding this letter, please contact Mr. Greg Cecil, Senior Financial Analyst, at 402-492-3148. Sincerely, Digitally signed by: ��� �Francis Tim Severin l ( Date: 2020.07.13 07:27:15-05'00' Tim Severin Director Community Planning and Development Division