Audit 12214

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.