How Do I...Minimize funding clawbacks or adverse audit findings?

A curated list of Questions & Answers to help cities minimize funding clawbacks or adverse audit findings.

Compliance & Reporting, CSLFRF

Is it permissible to report expenditures incurred by a sub-recipient prior to the award date? If so, how should "term-start date" be defined?

Compliance & Reporting, Program Administration, American Rescue Plan Act, CARES Act, CSLFRF, FEMA, HUD, Infrastructure Investments and Jobs Act

How can municipalities balance the need to build community capacity with the need to move quickly on grant deadlines?

Compliance & Reporting, Due Diligence & Fraud Protection, American Rescue Plan Act, CARES Act, CSLFRF, FEMA, HUD, Infrastructure Investments and Jobs Act

Should a municipality consider conducting risk assessments as part of its audit strategy?

Compliance & Reporting, American Rescue Plan Act, CARES Act, CSLFRF, FEMA, HUD, Infrastructure Investments and Jobs Act

Is it appropriate for a consultant or other entity who offered free grant application assistance to later be considered in a competitive bidding process? What steps should a municipality take to mitigate the risk or appearance of misconduct?

Compliance & Reporting, Due Diligence & Fraud Protection, American Rescue Plan Act, CARES Act, CSLFRF, FEMA, HUD, Infrastructure Investments and Jobs Act

How should a municipality prepare for an audit by an Office of the Inspector General (“OIG”) for a program administered by a prior administration that focuses on due diligence and proper record keeping?

Compliance & Reporting, Infrastructure & Maintenance Investments, American Rescue Plan Act, CARES Act, CSLFRF, FEMA, HUD, Infrastructure Investments and Jobs Act

What good practices should municipalities follow in identifying applicable federal code provisions that they would be required to comply with when allocating and using federal transportation infrastructure funding?

Compliance & Reporting, Due Diligence & Fraud Protection, American Rescue Plan Act, CARES Act, CSLFRF, FEMA, HUD, Infrastructure Investments and Jobs Act

What are good practices for municipalities to put in place after completing a federal audit to better position them for future federal audits?

Compliance & Reporting, Due Diligence & Fraud Protection, CSLFRF

When a contractor, vendor, or supplier of a municipality’s CSLFRF grant award commits fraud, is the municipality required to establish new internal oversight controls for future award?

Compliance & Reporting, CSLFRF

Under reporting requirements established by Expenditure Category 1.8 and 2.29, how can a municipality submit reporting data for a small business beneficiary that has been awarded over $50,000 when the small business does not have an EIN or TIN?

Compliance & Reporting, Fund Planning & Allocation, American Rescue Plan Act, CSLFRF

Are cities permitted to include payroll expenses in the cost of an entire project? When reporting project expenditures, should labor expenses be separated into the "labor" expenditure category, or be included in the reporting for the project itself?