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We reviewed the allocation process and monitoring of emergency COVID-related service grants the City has made using funding from the U.S. Department of Housing and Urban Development (HUD) and the State of California. This preliminary review, the third in a series on emergency expenses,1 aims to support cost recovery oversight, including compliance with federal and state record-keeping, procurement, and audit requirements, as outlined in the Recovery Annex of the City’s Emergency Operations Plan.

We recommend that the City Council accept the City Auditor’s preliminary review of documentation for COVID-19 related costs to support receipt of emergency public assistance through the federal Coronavirus Relief Fund (CRF).

We recommend that the City Council accept the City Auditor’s interim report on the status of internal controls for documenting COVID-19 related costs to support receipt of emergency public assistance grants through the Federal Emergency Management Agency (FEMA).

The purpose of this document is to describe the general regulatory and internal control framework the City of Sacramento will operate under for the City’s COVID-19 response and all COVID-19 related activities. This document is an essential resource for the City as it identifies key COVID-19 regulatory and internal control information that can aid in maximizing the City’s eligibility for State and Federal resources. This document is a general guide for the City to use.

The Office has reviewed two of the Governor’s decisions regarding the spending of Coronavirus Relief Fund (CRF) dollars. We are providing this guidance now to ensure the Governor has an opportunity to correct identified spending that does not comply or may not comply with use restrictions. We have also consulted with The United States Treasury Office of the Inspector General to confirm our conclusions.

The City of Sacramento will be subject to future audits of State and Federal funds, such as the Coronavirus Relief Fund or FEMA Public Assistance. These audits would likely be conducted by an Inspector General’s Office or the Government Accountability Office. The key to successfully withstanding any future audit will be the City’s ability to provide sufficient and appropriate documentation supporting the use of these funds.

The objective of these assessments is to help the City prepare for State and Federal audits of the City’s use of emergency funding. This includes proactive and real-time assistance in complying with regulatory requirements, securing reimbursements, tracking disaster recovery costs, and evaluating whether funds are being used efficiently and effectively.

The economic shutdowns in early 2020 led to historically high numbers of UI claims in a very short time (claim surge), and further shutdowns began in December 2020, raising the potential for additional spikes in unemployment. This audit reviewed EDD’s response to the claim surge, its handling of the resulting backlog of unpaid claims, and the assistance it has provided to individuals through its call center

Since the surge in pandemic‑related California unemployment claims began in March 2020, individuals, news organizations, and law enforcement officials have reported many cases of potential and actual UI fraud. Not surprisingly, the pandemic conditions increased EDD’s UI workloads and also resulted in changes to federal UI benefit programs, both of which have created a greater risk of fraud.

This report concludes that the five courts we reviewed for this audit—the superior courts in Alameda, Contra Costa, Lake, Orange, and San Bernardino counties—adhered to most of the required and recommended procurement and contracting practices that we evaluated, but they could improve in certain areas.