Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also
§200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: The Village allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 12 of the 60 samples selected for testing within Housing Opportunities for Persons with AIDS, did not have sufficient support for the allocation of the costs, or the costs themselves.
Cause: The Village did not have policies and procedures in place to ensure that sufficient documentation was maintained to support the allocation of costs.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Housing Opportunities for Persons with AIDS: $6,830 Likely Questioned Costs Housing Opportunities for Persons with AIDS: $234,595
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2022 were $1,173,061. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that sufficient documentation be maintained to support any allocations of costs as required by §200.403.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet and implementing new procedures to ensure accurate expenditure reporting.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also
§200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: The Village allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 12 of the 60 samples selected for testing within Housing Opportunities for Persons with AIDS, did not have sufficient support for the allocation of the costs, or the costs themselves.
Cause: The Village did not have policies and procedures in place to ensure that sufficient documentation was maintained to support the allocation of costs.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Housing Opportunities for Persons with AIDS: $6,830 Likely Questioned Costs Housing Opportunities for Persons with AIDS: $234,595
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2022 were $1,173,061. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that sufficient documentation be maintained to support any allocations of costs as required by §200.403.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet and implementing new procedures to ensure accurate expenditure reporting.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218
Program: CDBG-Entitlement Grants Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, per the Uniform Guidance in 2 CFR §200.313, Equipment, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR §200.313(d)(2)).
Condition: Of the one transaction subject to equipment real property management requirements in 2022 we noted that:
(1) There is no separate listing of equipment purchased using federal funds being maintained. However, no additional equipment was noted and no sales of equipment purchased with federal funding occurred in 2022.
(2) No physical inventory count was performed for equipment purchased using federal funds in 2022. However, one would not be considered overdue until 2023.
Cause: The Village does not have adequate policies and procedures in place regarding monitoring of equipment acquired under Federal awards.
Effect or Potential Effect: There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with the specified requirements of one transaction.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that Village implement policies, procedures, and controls that will ensure that equipment purchased under Federal awards are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies regarding Equipment and Real Property management.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218
Program: CDBG-Entitlement Grants Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, per the Uniform Guidance in 2 CFR §200.313, Equipment, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR §200.313(d)(2)).
Condition: Of the one transaction subject to equipment real property management requirements in 2022 we noted that:
(1) There is no separate listing of equipment purchased using federal funds being maintained. However, no additional equipment was noted and no sales of equipment purchased with federal funding occurred in 2022.
(2) No physical inventory count was performed for equipment purchased using federal funds in 2022. However, one would not be considered overdue until 2023.
Cause: The Village does not have adequate policies and procedures in place regarding monitoring of equipment acquired under Federal awards.
Effect or Potential Effect: There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with the specified requirements of one transaction.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that Village implement policies, procedures, and controls that will ensure that equipment purchased under Federal awards are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies regarding Equipment and Real Property management.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218
Program: CDBG-Entitlement Grants Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, per the Uniform Guidance in 2 CFR §200.313, Equipment, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR §200.313(d)(2)).
Condition: Of the one transaction subject to equipment real property management requirements in 2022 we noted that:
(1) There is no separate listing of equipment purchased using federal funds being maintained. However, no additional equipment was noted and no sales of equipment purchased with federal funding occurred in 2022.
(2) No physical inventory count was performed for equipment purchased using federal funds in 2022. However, one would not be considered overdue until 2023.
Cause: The Village does not have adequate policies and procedures in place regarding monitoring of equipment acquired under Federal awards.
Effect or Potential Effect: There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with the specified requirements of one transaction.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that Village implement policies, procedures, and controls that will ensure that equipment purchased under Federal awards are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies regarding Equipment and Real Property management.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.406 requires that non-Federal entities receiving Federal awards must reduce the funds requested by any applicable credits.
Per 2 CFR §200.406 Applicable Credits:
“(a) Applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect (F&A) costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate.”
Condition: During our testing over nonpayroll costs, for one out of 60 selections, the Village requested reimbursement for an eligible expenditure. However, the item was reimbursed by the vendor through a credit to the Village’s account from an item previously reimbursed. The original credit was required to be returned to the grantor upon receipt.
Cause: The Village did not maintain internal control procedures to ensure that credits reduced the funds requested.
Effect or Potential Effect: The Village charged through expenditures that were not appropriately reduced by vendor credits, which could result in disallowances or costs reimbursed in excess of costs incurred.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend the Village implements internal controls to ensure any credits are not requested for reimbursement or are refunded, as appropriate, to the Federal agency.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies over the proper treatment of credit memos obtained and the timely return of funds to the grantor.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.406 requires that non-Federal entities receiving Federal awards must reduce the funds requested by any applicable credits.
Per 2 CFR §200.406 Applicable Credits:
“(a) Applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect (F&A) costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate.”
Condition: During our testing over nonpayroll costs, for one out of 60 selections, the Village requested reimbursement for an eligible expenditure. However, the item was reimbursed by the vendor through a credit to the Village’s account from an item previously reimbursed. The original credit was required to be returned to the grantor upon receipt.
Cause: The Village did not maintain internal control procedures to ensure that credits reduced the funds requested.
Effect or Potential Effect: The Village charged through expenditures that were not appropriately reduced by vendor credits, which could result in disallowances or costs reimbursed in excess of costs incurred.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend the Village implements internal controls to ensure any credits are not requested for reimbursement or are refunded, as appropriate, to the Federal agency.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies over the proper treatment of credit memos obtained and the timely return of funds to the grantor.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.430(i) states that “charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain all records for timesheet approvals by the employee and/or direct supervisor. We noted 7 out of 60 samples selected for testing within the Housing Opportunities for Persons with AIDS, that did not have documentation of employee and/or supervisor approval.
Cause: The Village’s record retention policy within its payroll system allows for certain details related to timecards and employee and supervisor approvals to be deleted after one year. Because of this policy, records were not available for inspection during the audit to verify that costs were appropriately reviewed and approved in accordance with 2 CFR 200.430.
Effect or Potential Effect: The Village could not provide appropriate evidence to verify that internal controls functioned during the audit period and costs were charged to the federal program in accordance with the requirements of 2 CFR.430.
Questioned Costs:
Known Questioned Costs: None above the $25,000 reporting threshold. Likely Questioned Costs: None above the $25,000 reporting threshold.
Context: Payroll costs including fringe benefits in 2022 were $708,148 with known questioned costs of $373 and likely questioned costs of $15,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently retain timesheet records and approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping. The record retention policy for timesheets will be extended.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.430(i) states that “charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain all records for timesheet approvals by the employee and/or direct supervisor. We noted 7 out of 60 samples selected for testing within the Housing Opportunities for Persons with AIDS, that did not have documentation of employee and/or supervisor approval.
Cause: The Village’s record retention policy within its payroll system allows for certain details related to timecards and employee and supervisor approvals to be deleted after one year. Because of this policy, records were not available for inspection during the audit to verify that costs were appropriately reviewed and approved in accordance with 2 CFR 200.430.
Effect or Potential Effect: The Village could not provide appropriate evidence to verify that internal controls functioned during the audit period and costs were charged to the federal program in accordance with the requirements of 2 CFR.430.
Questioned Costs:
Known Questioned Costs: None above the $25,000 reporting threshold. Likely Questioned Costs: None above the $25,000 reporting threshold.
Context: Payroll costs including fringe benefits in 2022 were $708,148 with known questioned costs of $373 and likely questioned costs of $15,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently retain timesheet records and approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping. The record retention policy for timesheets will be extended.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster during 2022 based on budget allocation rates or employees’ schedules. For the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster, the majority of employees did not track actual time and effort for comparison to budget allocations or employees’ schedules. There was no procedure in place to determine if a true-up was necessary from allocated costs. 180 timesheets were tested during the audit (60 for each program). All 60 were charged based on employee schedules for Health Center Program Cluster. 59 timesheets of the 60 tested were charged based on budgets for the CDBG-Entitlement Grants Cluster. Lastly, 45 timesheets of the 60 tested were based on budgets for the Emergency Solutions Grants Program.
Cause: The Village did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, and the Health Center Program Cluster to the actual expenditures incurred.
Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known CDBG-Entitlement Grants Cluster: $16,765 Likely CDBG-Entitlement Grants Cluster: $842,671 Known Emergency Solutions Grants Program: $9,453 Likely Emergency Solutions Grants Program: $1,646,760 Known Health Center Cluster Program: $27,601
Likely Health Center Cluster Program: $2,133,947
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Any payroll costs not adequately support by time and effort reports are considered questioned costs.
Identification as a Repeat Finding: 2021-007.
Recommendation: We recommend that the Village implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also
§200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: The Village allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 12 of the 60 samples selected for testing within Housing Opportunities for Persons with AIDS, did not have sufficient support for the allocation of the costs, or the costs themselves.
Cause: The Village did not have policies and procedures in place to ensure that sufficient documentation was maintained to support the allocation of costs.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Housing Opportunities for Persons with AIDS: $6,830 Likely Questioned Costs Housing Opportunities for Persons with AIDS: $234,595
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2022 were $1,173,061. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that sufficient documentation be maintained to support any allocations of costs as required by §200.403.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet and implementing new procedures to ensure accurate expenditure reporting.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also
§200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: The Village allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 12 of the 60 samples selected for testing within Housing Opportunities for Persons with AIDS, did not have sufficient support for the allocation of the costs, or the costs themselves.
Cause: The Village did not have policies and procedures in place to ensure that sufficient documentation was maintained to support the allocation of costs.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Housing Opportunities for Persons with AIDS: $6,830 Likely Questioned Costs Housing Opportunities for Persons with AIDS: $234,595
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2022 were $1,173,061. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that sufficient documentation be maintained to support any allocations of costs as required by §200.403.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet and implementing new procedures to ensure accurate expenditure reporting.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218, 14.267
Program: CDBG-Entitlement Grants Cluster, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 6 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308. We noted that 7 of the 127 samples selected for testing within the CDBG-Entitlement Grants Cluster, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs:
Known Questioned Costs Continuum of Care: $5,666 Likely Questioned Costs Continuum of Care: $135,894
Known Questioned Costs CDBG-Entitlement Grants Cluster: $5,770 Likely Questioned Costs CDBG-Entitlement Grants Cluster: $33,675
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Costs in the first and last months of the grant period for the Continuum of Care Program in 2022 were $847,523. Costs in the first month of the grant period for the CDBG-Entitlement Grants Cluster in 2022 were $59,606.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-009.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services.
Federal Assistance Listing Numbers: 14.231, 93.224 & 93.527.
Programs: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster.
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6.
Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with
§200.317 through §200.327.
In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity.
Condition: The Village’s procurement policy does not have a level of specificity to fully comply with Federal procurement regulations. The Village has an organization wide procurement process. However, the records do not adequately differentiate between procurement for federal grants and other funding sources. The Village was unable to provide vendor selection documentation of the bidding process associated with two of the two transactions selected for the Emergency Solutions Grants Program, and four of the four selections for the Health Center Program Cluster. Additionally, the Village’s written processes do not have specific control procedures to check for suspension and debarment and, therefore, the Village did not verify that vendors or contractors were not excluded or disqualified prior to entering into these arrangements. During the audit, vendors were subsequently checked for suspension and debarment and no ineligible vendors were noted.
Cause: The Village’s personnel did not adhere to the Village’s documented policies and procedures for ensuring complete documentation of the history of the procurement and the Village did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred prior to entering into those agreements.
Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with Federal regulations and the Village’s policy. Potential for entering into contracts with suspended or debarred vendors.
Questioned Costs:
Known Questioned Costs Health Center Program Cluster: $146,704 Known Questioned Costs Emergency Solutions Grants Program: $680,586 Likely Questioned Costs Emergency Solutions Grants Program: $943,378
Context: This is a condition identified per review of the Village’s compliance with specified requirements on a policy level and testing of representative transactions. The total population for procurement testing was $146,704 for the Health Center Program Cluster. All four transactions subject to procurement were selected for testing and did not have proper documentation to support the procurement decision. The total population for procurement testing was $943,378 for the Emergency Solutions Grants Program. Two transactions selected for testing subject to procurement did not have proper documentation to support the procurement decision.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-010.
Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Village’s procurement policy and Federal regulations as well as relevant suspension and debarment requirements included in §200.214.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of updating and strengthening policies and procedures over suspension, and debarment and retaining sufficient supporting documentation to support procurement
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-26, HHI-23-13
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.”
Per 24 CFR §§578.49(b)(2) and 578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: For 26 out of 60 rental payments tested, a comparable unit analysis was not completed for updated HUD Fair Market Rate’s (FMR) or lease modifications subsequent to move in. These amounts are excluded from questioned costs as it is not known if any rents were paid over the amount considered reasonable. For 16 out of the 60 rental payments tested, rent charges were unsupported by underlying leases, rent reasonableness forms, or rent charges were in excess of FMR, without appropriate waivers.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Additionally, not all supporting documentation for changes to terms were obtained or retained.
Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $9,720
Likely Questioned Costs: $261,268
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were calculated as the amounts paid above FMR or unsupported. Total costs subject to rent reasonableness were $2,125,224.
Identification as a Repeat Finding: 2021-011.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined fair market rents requirements.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.231, 14.241
Program: Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For the Housing Opportunities for Persons with AIDS, for 12 out of 60 sample selections, calculation errors were found in the request for reimbursement resulting in small differences between actual payroll costs and the amounts charged to the program. We also noted that in 14 of the 60 samples selections for the Emergency Solution Grant Program, had similar calculation errors. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors, and did not have an adequate review process to identify and correct calculation errors within the request for reimbursement.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Emergency Solutions Grants Program: $277 Likely Questioned Costs Emergency Solutions Grants Program: $44,276
Known Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Likely Questioned Costs Housing Opportunities for Persons with AIDS: None above the
$25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $1,529,275. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2022 were $708,148 with known questioned costs of $427 and likely questioned costs of $18,245.
Identification as a Repeat Finding: 2021-012.
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations within the requests for reimbursement prior to submission.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770, 19H80CS10606, 21H8FCS40355C6
Criteria: Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain the records for timesheet approvals by the employee and/or direct supervisor. We noted in accordance with §200.430(i) that 34 out of 60 samples selected for testing within the Community Development Grants Program, did not have employee and/or supervisor approval. We noted 19 out of 60 samples selected for testing within the Health Center Program Cluster, that did not have documentation of employee and/or supervisor approval. We noted 44 out of 60 samples selected for testing within the Emergency Solutions Grants Program, did not have documentation of employee and/or supervisor approval.
Cause: The Village did not have policies and procedures in place to timely receive and retain sufficient documentation over the approval of timesheets.
Effect or Potential Effect: Without adequate controls in place to ensure timesheets are adequately reviewed and approved, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Known Questioned Costs Community Development Block Grant: $7,528 Likely Questioned Costs Community Development Block Grant: $378,395 Known Questioned Costs Health Center Program Cluster: $16,397
Likely Questioned Costs Health Center Program Cluster: $1,267,711 Known Questioned Costs Emergency Solutions Grants Program: $9,472 Likely Questioned Costs Emergency Solutions Grants Program: $1,649,038
Context: Payroll costs including fringe benefits for the CDBG-Entitlement Grants Cluster in 2022 were $848,919. Payroll costs including fringe benefits for the Emergency Solutions Grants Program in 2022 were $2,052,649. Payroll costs including fringe benefits for the Health Center Program Cluster in 2022 were $2,133,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently obtain and retain timesheet approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.218, 14.231, 14.241, 14.267, 93.224 & 93.527
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program, Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-03, HHI-21-35, HHI-20-21, 563770, 558951, CA0802L9D012012, CA0802L9D012113, CA1348L9D012006, CA1348L9D012107, CA1510L9D012005, CA1510L9D012106, CA1883L9D012001, CA1883L9D012102, HHI-22-07, HHI-23-03, HHI-22-26, HHI-23-13, 19H80CS10606, 21H8FCS40355C6
Criteria: The Uniform Guidance in 2 CFR §200.512, Report submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period.
Condition: The Village did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022.
Cause: The Village did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Effect or Potential Effect: The Village could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Questioned Costs: None.
Context: This was a condition noted per review of Villages’ compliance with the specified requirements. The submission was due September 30, 2023.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials: Management agrees with the finding. Management has experienced significant turnover in recent years and is working to enhance the internal accounting team to expedite year end close processes.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218
Program: CDBG-Entitlement Grants Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, per the Uniform Guidance in 2 CFR §200.313, Equipment, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR §200.313(d)(2)).
Condition: Of the one transaction subject to equipment real property management requirements in 2022 we noted that:
(1) There is no separate listing of equipment purchased using federal funds being maintained. However, no additional equipment was noted and no sales of equipment purchased with federal funding occurred in 2022.
(2) No physical inventory count was performed for equipment purchased using federal funds in 2022. However, one would not be considered overdue until 2023.
Cause: The Village does not have adequate policies and procedures in place regarding monitoring of equipment acquired under Federal awards.
Effect or Potential Effect: There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with the specified requirements of one transaction.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that Village implement policies, procedures, and controls that will ensure that equipment purchased under Federal awards are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies regarding Equipment and Real Property management.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218
Program: CDBG-Entitlement Grants Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, per the Uniform Guidance in 2 CFR §200.313, Equipment, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR §200.313(d)(2)).
Condition: Of the one transaction subject to equipment real property management requirements in 2022 we noted that:
(1) There is no separate listing of equipment purchased using federal funds being maintained. However, no additional equipment was noted and no sales of equipment purchased with federal funding occurred in 2022.
(2) No physical inventory count was performed for equipment purchased using federal funds in 2022. However, one would not be considered overdue until 2023.
Cause: The Village does not have adequate policies and procedures in place regarding monitoring of equipment acquired under Federal awards.
Effect or Potential Effect: There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with the specified requirements of one transaction.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that Village implement policies, procedures, and controls that will ensure that equipment purchased under Federal awards are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies regarding Equipment and Real Property management.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.218
Program: CDBG-Entitlement Grants Cluster
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, per the Uniform Guidance in 2 CFR §200.313, Equipment, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR §200.313(d)(2)).
Condition: Of the one transaction subject to equipment real property management requirements in 2022 we noted that:
(1) There is no separate listing of equipment purchased using federal funds being maintained. However, no additional equipment was noted and no sales of equipment purchased with federal funding occurred in 2022.
(2) No physical inventory count was performed for equipment purchased using federal funds in 2022. However, one would not be considered overdue until 2023.
Cause: The Village does not have adequate policies and procedures in place regarding monitoring of equipment acquired under Federal awards.
Effect or Potential Effect: There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with the specified requirements of one transaction.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that Village implement policies, procedures, and controls that will ensure that equipment purchased under Federal awards are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies regarding Equipment and Real Property management.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.406 requires that non-Federal entities receiving Federal awards must reduce the funds requested by any applicable credits.
Per 2 CFR §200.406 Applicable Credits:
“(a) Applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect (F&A) costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate.”
Condition: During our testing over nonpayroll costs, for one out of 60 selections, the Village requested reimbursement for an eligible expenditure. However, the item was reimbursed by the vendor through a credit to the Village’s account from an item previously reimbursed. The original credit was required to be returned to the grantor upon receipt.
Cause: The Village did not maintain internal control procedures to ensure that credits reduced the funds requested.
Effect or Potential Effect: The Village charged through expenditures that were not appropriately reduced by vendor credits, which could result in disallowances or costs reimbursed in excess of costs incurred.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend the Village implements internal controls to ensure any credits are not requested for reimbursement or are refunded, as appropriate, to the Federal agency.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies over the proper treatment of credit memos obtained and the timely return of funds to the grantor.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.406 requires that non-Federal entities receiving Federal awards must reduce the funds requested by any applicable credits.
Per 2 CFR §200.406 Applicable Credits:
“(a) Applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect (F&A) costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate.”
Condition: During our testing over nonpayroll costs, for one out of 60 selections, the Village requested reimbursement for an eligible expenditure. However, the item was reimbursed by the vendor through a credit to the Village’s account from an item previously reimbursed. The original credit was required to be returned to the grantor upon receipt.
Cause: The Village did not maintain internal control procedures to ensure that credits reduced the funds requested.
Effect or Potential Effect: The Village charged through expenditures that were not appropriately reduced by vendor credits, which could result in disallowances or costs reimbursed in excess of costs incurred.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend the Village implements internal controls to ensure any credits are not requested for reimbursement or are refunded, as appropriate, to the Federal agency.
Views of Responsible Officials: Management agrees with the finding. Management will enhance and enforce existing policies over the proper treatment of credit memos obtained and the timely return of funds to the grantor.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: HHI-22-07, HHI-23-03
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: For 34 out of 40 selections of the rent expenditures requested, appropriate supporting documentation was not available to support the reasonableness of the amount paid and appropriate period of performance of the rent costs requested for reimbursement.
Cause: The Village did not appropriately retain or produce documentation that rent reasonableness was determined prior to submitting for reimbursement.
Effect or Potential Effect: Insufficient retention of underlying lease documents resulted in controls not operating effectively to appropriately identify rental amounts for the Village’s clients in need of rental assistance. The Village could incorrectly charge expenditures to the federal program as a result.
Questioned Costs:
Known Questioned Costs: $13,926
Likely Questioned Costs: $668,925
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the grant subject to testing were $925,334. Questioned costs were calculated as amounts lacking documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village enforce existing policies and procedures and implement additional policies and procedures for maintaining lease documentation.
Views of Responsible Officials: Management agrees with the finding. Management is implementing a check on all claims to ensure proper period of performance for grants.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.218, 14.231
Program: CDBG-Entitlement Grants Cluster, Emergency Solutions Grants Program, COVID-19 Emergency Solutions Grants Program
Award/Pass-Through Entity Identifying Numbers: HHI-21-03, HHI-22-21, NCIP-FY20-010, HHI-21-35, HHI-20-21, 563770
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §200.300 through §200.309.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: During our testing of costs (excluding payroll and fringe benefits, see finding 2022-004), we noted in accordance with §200.403(g) that 10 of the 60 samples selected for testing within CDBG- Entitlement Grants Cluster, did not have sufficient support for their rationale regarding the allocation of the costs. For the Emergency Solutions Grants Program, 29 of the 60 samples selected for testing did not have sufficient support for their rationale regarding the allocation of the costs.
Cause: The Village allocates many costs between individual grants and grant programs, without maintaining adequate support for the rationale behind the allocation of costs.
Effect or Potential Effect: Without adequate support for the rationale behind cost allocations, the Village cannot adequately document that costs are fairly charged between individual grants and grant programs. The Village could charge expenses to federal programs that are not based on the programs usage.
Questioned Costs:
Known Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Likely Questioned Costs CDBG-Entitlement Grants Cluster: None above the $25,000 reporting threshold.
Known Questioned Costs Emergency Solutions Grants Program: $6,232 Likely Questioned Costs Emergency Solutions Grants Program: $38,701
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the CDBG-Entitlement Grants Cluster in 2022 were $444,085 with known questioned costs of $7,732 and likely questioned costs of $20,400. Nonpayroll costs for the Emergency Solutions Grants Program in 2022 were
$1,854,771. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: This is a repeat of prior year finding 2021-008.
Recommendation: We recommend that the Village carefully document the rationale or justification for cost allocations.
Views of Responsible Officials: Management agrees with this finding. Management is developing a cost allocation worksheet, which will include documentation for the rationale or justification for cost allocations.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.430(i) states that “charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain all records for timesheet approvals by the employee and/or direct supervisor. We noted 7 out of 60 samples selected for testing within the Housing Opportunities for Persons with AIDS, that did not have documentation of employee and/or supervisor approval.
Cause: The Village’s record retention policy within its payroll system allows for certain details related to timecards and employee and supervisor approvals to be deleted after one year. Because of this policy, records were not available for inspection during the audit to verify that costs were appropriately reviewed and approved in accordance with 2 CFR 200.430.
Effect or Potential Effect: The Village could not provide appropriate evidence to verify that internal controls functioned during the audit period and costs were charged to the federal program in accordance with the requirements of 2 CFR.430.
Questioned Costs:
Known Questioned Costs: None above the $25,000 reporting threshold. Likely Questioned Costs: None above the $25,000 reporting threshold.
Context: Payroll costs including fringe benefits in 2022 were $708,148 with known questioned costs of $373 and likely questioned costs of $15,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently retain timesheet records and approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping. The record retention policy for timesheets will be extended.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS
Award/Pass-Through Entity Identifying Numbers: 558951
Criteria: The Uniform Guidance in 2 CFR §200.430(i) states that “charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non-Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: The Village did not maintain all records for timesheet approvals by the employee and/or direct supervisor. We noted 7 out of 60 samples selected for testing within the Housing Opportunities for Persons with AIDS, that did not have documentation of employee and/or supervisor approval.
Cause: The Village’s record retention policy within its payroll system allows for certain details related to timecards and employee and supervisor approvals to be deleted after one year. Because of this policy, records were not available for inspection during the audit to verify that costs were appropriately reviewed and approved in accordance with 2 CFR 200.430.
Effect or Potential Effect: The Village could not provide appropriate evidence to verify that internal controls functioned during the audit period and costs were charged to the federal program in accordance with the requirements of 2 CFR.430.
Questioned Costs:
Known Questioned Costs: None above the $25,000 reporting threshold. Likely Questioned Costs: None above the $25,000 reporting threshold.
Context: Payroll costs including fringe benefits in 2022 were $708,148 with known questioned costs of $373 and likely questioned costs of $15,947. Questioned costs consist of amounts lacking documentation of fully approved timesheets.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village consistently retain timesheet records and approvals by both the employee and supervisor for each pay period requested for reimbursement by the grantor. These records should be maintained at least through the close out of the grant and completion of required audits.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of upgrading the system utilized for time and entry allocations to grants to ensure accurate and timely time entry record keeping. The record retention policy for timesheets will be extended.