OIG-CA-23-010
- Document type
- Memorandum
- Date
- 2023-01-31
This source document is titled OIG-CA-23-010 and is classified in controlled metadata as oversight_report.
Full text
OFFICE OF
INSPECTOR GENERAL
DEPARTM ENT OF THE TREASURY
WASHINGTON, D.C. 20220
January 31, 2023
MEMORANDUM FOR MR. JACOB LEIBENLUFT, CHIEF RECOVERY OFFICER
FROM:
Deborah L. Harker /s/
Assistant Inspector General for Audit
SUBJECT:
Desk Review of Broward County, FL Use of Coronavirus
Relief Fund Proceeds (OIG-CA-23-010)
Please find the attached desk review memorandum1 on Broward County, FL’s
(Broward County) use of Coronavirus Relief Fund (CRF) proceeds. The CRF is
authorized under Title VI of the Social Security Act, as amended by Title V Division
A of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Under a
contract monitored by our office, Castro & Company, LLC (Castro), a certified
independent public accounting firm, performed the desk review. Castro performed
the desk review in accordance with the Council of the Inspectors General on
Integrity and Efficiency, Quality Standards for Federal Offices of Inspector General.
Based on a review of Broward County’s documentation supporting the uses of CRF
proceeds, Castro determined that the expenditures comply with the CARES Act
and Treasury’s Guidance and that Broward County’s risk of unallowable use of
funds is low. As such, Castro is not recommending Treasury Office of Inspector
General perform an audit of Broward County.
In connection with the contract, we reviewed Castro’s desk review memorandum
and related documentation and inquired of its representatives. Our review, as
differentiated from an audit performed in accordance with generally accepted
government auditing standards, was not intended to enable us to express an
opinion on Broward County’s use of the CRF proceeds. Castro is responsible for the
attached desk review memorandum and the conclusions expressed therein. Our
review found no instances in which Castro did not comply in all material respects,
with quality standards for Federal Offices of Inspector General.
We appreciate the courtesies and cooperation provided to Castro and our staff
during the desk review. If you have any questions or require further information,
1 The CARES Act assigned the Department of the Treasury, Office of Inspector General with
responsibility for compliance monitoring and oversight of the receipt, disbursement, and use of CRF
payments. The purpose of the desk review is to perform monitoring procedures of the prime
recipient’s receipt, disbursements, and uses of CRF proceeds as reported in the GrantSolutions
portal on a quarterly basis.
Page 2
please contact me at (202) 486-1420, or a member of your staff may contact Lisa
DeAngelis, Deputy Assistant Inspector General for Audit, at (202) 487-8371.
Attachment
cc:
Michelle. A. Dickerman, Deputy Assistant General Counsel, Department of
the Treasury
Victoria Collin, Chief Compliance & Finance Officer, Office of Recovery
Programs, Department of the Treasury
George Tablack, Broward County Director of Finance
Wayne Ference, Partner, Castro & Company, LLC
Desk Review of the County of Broward
1
1635 King Street
Alexandria, VA 22314
Phone: 703.229.4440
Fax: 703.859.7603
www.castroco.com
January 31, 2023
OIG-CA-23-010
MEMORANDUM FOR DEBORAH L. HARKER,
ASSISTANT INSPECTOR GENERAL FOR AUDIT
FROM:
Wayne Ference, Partner, Castro & Company, LLC
SUBJECT:
Desk Review of the County of Broward, Florida
On May 26, 2022, we initiated a desk review of the County of Broward, Florida’s
(herein referred to as ‘Broward County’) use of the Coronavirus Relief Fund (CRF)
authorized under Title VI of the Social Security Act, as amended by Title V Division
A of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act)1. The
objective of our desk review was to evaluate Broward County’s documentation
supporting its uses of CRF proceeds as reported in the GrantSolutions2 portal and
to assess the risk of unallowable use of funds. The scope of the desk review was
limited to obligation and expenditure data for the period of March 1, 2020 through
March 31, 2022, as reported in Cycles 1 through 8 in the GrantSolutions portal.
As part of our desk review, we performed the following:
1) reviewed Broward County’s quarterly Financial Progress Reports (FPRs)
submitted in the GrantSolutions portal through June 30, 2021. As all of
Broward County’s CRF proceeds were expended as of Cycle 5, there were
no additional FPRs available for Cycles 6 through 8;
2) reviewed the Department of the Treasury’s (Treasury) Coronavirus Relief
Fund Guidance as published in the Federal Register on January 15, 20213;
1 P.L. 116-136 (March 27, 2020)
2 GrantSolutions, a grant and program management Federal shared service provider under the
U.S. Department of Health and Human Services, developed a customized and user-friendly
reporting solution to capture the use of CRF payments from recipients.
3 Coronavirus Relief Fund Guidance as published in the Federal Register (January 15, 2021)
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-00827.pdf
Desk Review of the County of Broward
2
3) reviewed Treasury Office of Inspector General (OIG) Coronavirus Relief
Fund Frequently Asked Questions Related to Reporting and Recordkeeping4;
4) reviewed Treasury OIG’s monitoring checklists5 of Broward County’s
quarterly FPR submissions for reporting deficiencies;
5) reviewed other audit reports issued, such as Single Audit reports, and those
issued by the Government Accountability Office and other applicable
Federal agency OIGs for internal control or other deficiencies that may pose
risk or impact Broward County’s uses of CRF proceeds;
6) reviewed Treasury OIG Office of Investigations, the Council of the
Inspectors General on Integrity and Efficiency Pandemic Response
Accountability Committee (PRAC)6, and Treasury OIG Office of Counsel
input on issues that may pose risk or impact Broward County’s uses of CRF
proceeds;
7) interviewed key personnel responsible for preparing and certifying Broward
County’s GrantSolutions portal quarterly FPR submissions, as well as
officials responsible for obligating and expending CRF proceeds;
8) made a non-statistical selection of aggregate payments to individuals7 data
identified through GrantSolutions reporting; and
9) evaluated documentation and records used to support Broward County’s
quarterly FPRs.
Based on the results of our desk review, documentation supporting the uses of
CRF proceeds comply with the CARES Act and Treasury’s Guidance. Additionally,
Broward County’s risk of unallowable use of funds is low. As such, Castro is not
recommending Treasury OIG perform an audit of Broward County.
4 Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently Asked
Questions Related to Reporting and Recordkeeping OIG-20-028R; March 2, 2021
5 The checklists are used by the Treasury OIG to monitor the progress of prime recipient reporting
in the GrantSolutions portal. GrantSolutions quarterly submission reviews are designed to identify
material omissions and significant errors, and where necessary, include procedures for notifying
prime recipients of misreported data for timely correction. Treasury OIG follows the CRF Prime
Recipient Quarterly GrantSolutions Submissions Monitoring and Review Procedures Guide, OIG-
CA-20-029R to monitor the prime recipients quarterly.
6 Section 15010 of P.L. 116-136 established the Pandemic Response Accountability Committee
within the Council of the Inspectors General on Integrity and Efficiency to promote transparency
and conduct and support oversight of covered funds (see Footnote 13 for a definition of covered
funds) and the coronavirus response to (1) prevent and detect fraud, waste, abuse, and
mismanagement; and (2) mitigate major risks that cut across program and agency boundaries.
7 Obligations and expenditures for payments made to individuals, regardless of amount, are
required to be reported in the aggregate in the GrantSolutions portal to prevent inappropriate
disclosure of personally identifiable information.
Desk Review of the County of Broward
3
Non-Statistical Transaction Selection Methodology
Castro made a non-statistical selection of Aggregate Payments to Individuals.
Selections were made using auditor judgment based on information and risks
identified in reviewing audit reports, the GrantSolutions portal reporting
anomalies8 identified by the Treasury OIG CRF monitoring team, and review of
Broward County’s FPR submissions. Castro noted Broward County did not
obligate or expend CRF proceeds related to Contracts greater than or equal to
$50,000, Grants greater than or equal to $50,000, Loans greater than or equal to
$50,000, Transfers greater than or equal to $50,0009, Direct Payments greater than
or equal to $50,000 or Aggregate Reporting less than $50,00010; therefore, we did
not make a selection of transactions from these categories.
The number of transactions (10) we selected to test were based on Broward
County’s total CRF award amount and our overall risk assessment of Broward
County. Additionally, Treasury OIG did not identify any anomalies requiring
further testing.
Background
The CARES Act appropriated $150 billion to establish the CRF. Under the CRF,
Treasury made payments for specified uses to States; eligible units of local
governments; the District of Columbia; U.S. Territories, including the
Commonwealth of Puerto Rico, the United States Virgin Islands, Guam, American
Samoa, and the Commonwealth of the Northern Mariana Islands; and Tribal
governments. Treasury issued a CRF payment to Broward County for
$340,744,702.30. The CARES Act stipulates that a recipient may only use the funds
to cover costs that—
(1) are necessary expenditures incurred due to the public health emergency
with respect to the coronavirus disease 2019 (COVID-19);
(2) were not accounted for in the budget most recently approved as of
March 27, 2020; and
8 Treasury OIG has a pre-defined list of risk indicators that are triggered based on data submitted
by recipients in the FPR submissions that meet certain criteria. Castro reviewed these results
provided by Treasury OIG for Broward County.
9 A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
10 Recipients are required to report CRF transactions greater than or equal to $50,000 in detail in
the GrantSolutions portal. Transactions less than $50,000 can be reported as an aggregate lump-
sum amount by type (contracts, grants, loans, direct payments, and transfers to other government
entities).
Desk Review of the County of Broward
4
(3) were incurred between March 1, 2020 and December 31, 2021.11
Section 15011 of the CARES Act, requires each covered recipient12 to submit to
Treasury and the PRAC, no later than 10 days after the end of each calendar
quarter, a report that contains (1) the total amount of large covered funds13,14
received from Treasury; (2) the amount of large covered funds received that were
expended or obligated for each project or activity; (3) a detailed list of all projects
or activities for which large covered funds were expended or obligated; and (4)
detailed information on any level of subcontracts or subgrants awarded by the
covered recipient or its subcontracts or subgrantees.
The CARES Act assigned Treasury OIG the responsibility for compliance
monitoring and oversight of the receipt, disbursement, and use of CRF proceeds.
Treasury OIG also has authority to recoup funds in the event that it is determined
a recipient failed to comply with requirements of subsection 601(d) of the Social
Security Act, as amended, (42 U.S.C. 801(d)).
Desk Review Results
Our review of Broward County’s quarterly FPR submissions through June 30, 2021
did not identify reporting issues or variances. Transactions selected for detailed
review were supported by documentation and were allowable expenditures in
accordance with the CARES Act and Treasury’s guidance. We noted that the
tested aggregate payments to individuals were necessary expenditures due to the
COVID-19 public health emergency, were not accounted for in the budget most
recently approved as of March 27, 2020, and were incurred during the covered
period. The transactions selected for testing were not selected statistically, and
therefore results cannot be extrapolated to the total universe of transactions.
11 P.L. 116-260 (December 27, 2020). The period of performance end date of the CRF was extended
through December 31, 2021 by the Consolidated Appropriations Act, 2021. The period of
performance end date for tribal entities was further extended to December 31, 2022 by the State,
Local, Tribal, and Territorial Fiscal Recovery, Infrastructure, and Disaster Relief Flexibility Act,
Division LL of the Consolidated Appropriations Act, 2023, P.L. 117-328, December 29, 2022, 136
Stat. 4459.
12 Section 15011 of P.L. 116-136 defines a covered recipient as any entity that receives large
covered funds and includes any State, the District of Columbia, and any territory or possession of
the United States.
13 Section 15010 of P.L. 116-136 defines covered funds as any funds, including loans, that are made
available in any form to any non-Federal entity, not including an individual, under Public Laws 116-
123, 127, and 136, as well as any other law which primarily makes appropriations for Coronavirus
response and related activities.
14 Section 15011 of P.L. 116-136 defines large covered funds as covered funds that amount to more
than $150,000.
Desk Review of the County of Broward
5
Conclusion
*****
Based on our review of Broward County’s documentation supporting the uses of
CRF proceeds as reported in the GrantSolutions portal, we determined that the
expenditures comply with the CARES Act and Treasury’s Guidance. Additionally,
Broward County’s risk of unallowable use of funds is low. As such, Castro is not
recommending Treasury OIG perform an audit of Broward County.
All work completed with this letter complies with the Council of the Inspectors
General on Integrity and Efficiency’s Quality Standards for Federal Offices of
Inspectors General, which require that the work adheres to the professional
standards of independence, due professional care, and quality assurance to
ensure the accuracy of the information presented15. We appreciate the courtesies
and cooperation provided to our staff during the desk review.
Sincerely,
Wayne Ference
Partner, Castro & Company, LLC
15 https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdfFile and source
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