Audit 19499

FY End
2022-08-31
Total Expended
$5.98M
Findings
12
Programs
2
Organization: St. John's Commons, Inc. (MD)
Year: 2022 Accepted: 2023-07-26

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
24017 2022-001 Significant Deficiency Yes N
24018 2022-002 Material Weakness Yes N
24019 2022-003 Material Weakness Yes N
24020 2022-004 Material Weakness Yes N
24021 2022-005 Significant Deficiency Yes N
24022 2022-006 Material Weakness - N
600459 2022-001 Significant Deficiency Yes N
600460 2022-002 Material Weakness Yes N
600461 2022-003 Material Weakness Yes N
600462 2022-004 Material Weakness Yes N
600463 2022-005 Significant Deficiency Yes N
600464 2022-006 Material Weakness - N

Programs

Contacts

Name Title Type
NG5AFD1APZ73 Sheri Snyder Auditee
4109396456 Stewart Grubman Auditor
No contacts on file

Notes to SEFA

Title: Loan/loan guarantee outstanding balances Accounting Policies: Summary of Significant Accounting Policies Expenditures reported on the schedule of expenditures of federal awards (the Schedule) are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Schedule includes the federal award activity of St. John's Commons, Inc. (the Entity) under programs of the federal government for the year ended August 31, 2022. The information in this Schedule is presented in accordance with the requirements of The Uniform Guidance. Because the Schedule presents only a selected portion of the operations of the Entity, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Entity. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Entity has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The Entity is reimbursed for programmatic and administrative costs in accordance with rules set forth by the U.S. Department of Housing and Urban Development. SUPPORTIVE HOUSING FOR PERSONS WITH DISABILITIES (14.181) - Balances outstanding at the end of the audit period were $5,803,000.
Title: Federal Loan Program Accounting Policies: Summary of Significant Accounting Policies Expenditures reported on the schedule of expenditures of federal awards (the Schedule) are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Schedule includes the federal award activity of St. John's Commons, Inc. (the Entity) under programs of the federal government for the year ended August 31, 2022. The information in this Schedule is presented in accordance with the requirements of The Uniform Guidance. Because the Schedule presents only a selected portion of the operations of the Entity, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Entity. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Entity has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The Entity is reimbursed for programmatic and administrative costs in accordance with rules set forth by the U.S. Department of Housing and Urban Development. The Entity received a U.S. Department of Housing and Urban Development Capital Advance under Section 811 of the National Affordable Housing Act. The loan balance outstanding at the beginning of the year is included in the federal expenditures presented in the Schedule. The Entity received no additional loans during the year.

Finding Details

Finding No. 2022-001 ? Replacement Reserve Funding Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size 12 monthly payments Sample Size Information 12 monthly payments Identification of Repeat Finding Reference Number 2021-002 et seq. Criteria The regulatory agreement requires monthly payments of $1,640 to fund the replacement reserve. Statement of Condition The Entity was depositing the old required monthly payment rate of $1,562 and one monthly payment was not made to the replacement reserve during the year. Cause The cause of the incorrect deposit amount and missing payment was due to management oversight due to change in management personnel positions. Effect or Potential Effect The replacement reserve fund is underfunded by a total of $5,694. Auditor Non-Compliance Code N- Reserve for Replacements Deposits Questioned Costs There were no known questioned costs. Perspective The finding represents an instance of management oversight due to change in personnel. Repeat Finding Yes Recommendations Auditor recommends that the Entity fund the reserve immediately to make it current and create a better system of controls to ensure no further occurrences. Auditor notes deposit was made prior to issuance of the financial statements. No further action is required. Views of Responsible Officials Actions Taken or Planned - from Corrective Action Plan Auditee agrees with the finding and has made an additional deposit to the replacement reserve account in order to fully fund the reserve for replacements and has established a system of automatic monthly payments in order to properly fund the account going forward. Finding 2021-002 is cleared.
Finding No. 2022-002 ? Replacement Reserve Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size Replacement Reserve activity for the year ended August 31, 2022. Sample Size Information N/A Identification of Repeat Finding Reference Number 2021-003 Criteria In accordance with the Entity?s regulatory agreement with HUD, only upon approval from HUD can the Entity withdraw funds from the replacement reserve account. Statement of Condition The Entity withdrew $15,000 from the replacement reserve account without the approval of HUD. Cause Funds for unpaid vouchers for PRAC were withdrawn from replacement reserve and did not have the proper HUD approval for the withdrawals. Effect or Potential Effect The Entity is in violation of the requirements of its regulatory agreement. Auditor Non-Compliance Code A ? Unauthorized Withdrawals from the Replacement Reserve Account. Questioned Costs There were no known questioned costs. Perspective The finding is currently awaiting proper approval from the U.S. Department of Housing and Urban Development (?HUD?). Repeat Finding Yes Recommendations We recommend that management evaluate its process and implement policies to mitigate the chances of withdrawing funds from the replacement reserve without HUD approval. Views of Responsible Officials - from Corrective Action Plan Actions Taken or Planned Auditee agrees with this finding and has taken steps to prevent this from occurring in the future. A new Executive Director has taken over the responsibility for withdrawing funds as well as oversight from the Board of Directors. Auditee has been in discussion with HUD and will submit a letter with justification of withdrawals upon receipt of the notice of violation as requested by HUD. If accepted by HUD, this will clear this finding for the amount transferred during the fiscal year. Status of Corrective Action on Prior Findings Finding 2021-003 is cleared. A new Executive Director has taken over responsibility for withdrawing funds as well as oversight from the Board of Directors. A letter was submitted to HUD notifying them of the withdrawals by the previous director with a plan to correct. In addition to the letter, invoices were submitted to justify the transfers. HUD approval for the justification for the withdrawals was received on 2/21/2023 and 4/04/23. No amounts remain due to the account.
Finding No. 2022-003 ? Residual Receipts Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size Residual Receipts activity for the year ended August 31, 2022. Sample Size Information N/A Identification of Repeat Finding Reference Number 2021-004 Criteria In accordance with the Entity?s regulatory agreement with HUD, only upon approval from HUD can the Entity withdraw funds from the residual receipts account. Statement of Condition The Entity withdrew $127,309 from the residual receipts account without the approval of HUD. Cause Funds for repayment of minimum capital investment to Sponsor and operating expenses were withdrawn from residual receipts and did not have the proper HUD approval for the withdrawals. Effect or Potential Effect The Entity is in violation of the requirements of its regulatory agreement. Auditor Non-Compliance Code C ? Unauthorized Withdrawals from the Residual Receipts Account Questioned Costs There were no known questioned costs. Perspective The finding represents an instance of management oversight due to change in management personnel positions. Repeat Finding Yes Recommendations We recommend that management evaluate its process and implement policies to mitigate the chances of withdrawing funds from the residual receipts without HUD approval. Views of Responsible Officials -from corrective action plan. Actions Taken or Planned Auditee agrees with this finding and has taken steps to prevent this from occurring in the future. A new Executive Director has taken over the responsibility for withdrawing funds as well as oversight from the Board of Directors. Auditee has been in discussion with HUD and will submit a letter with justification of withdrawals upon receipt of the notice of violation as requested from HUD. If accepted by HUD, this will clear this finding for the amount transferred during this fiscal year.
Finding No. 2022-004 ? Timely Deposit of Surplus Cash Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size One (1) surplus cash deposit. Sample Size Information One (1) surplus cash deposit. Identification of Repeat Finding Reference Number 2017-001 et. seq. Criteria The regulatory agreement requires surplus cash payments to be deposited in the residual receipts reserve within 90 days of the fiscal year end. Statement of Condition The 2017 required surplus cash deposit was not made. Cause The cause of why the deposit was not made is due to management oversight due to change in management personnel positions. Effect or Potential Effect The requirement to deposit surplus cash within 90 days of the fiscal year end was not met. Auditor Non-Compliance Code B ? Failure to make required residual receipts deposits Questioned Costs There were no known questioned costs. Perspective The finding represents an instance of management oversight due to change in management personnel positions. Repeat Finding Yes Recommendations We recommend that management ensures the surplus cash deposit is done timely in the future. Views of Responsible Officials Actions Taken or Planned Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Going forward our focus will be to work with the auditor and owner to get the audits finalized earlier so adequate time is left for the deposits to be made. In instances where the final is not going to be issued and allow enough time, the deposit will be made based on the reviewed draft.
Finding No. 2022-005 ? Late Office of Management and Budget (OMB) Submission Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size One (1) OMB submission. Sample Size Information One (1) OMB submission. Identification of Repeat Finding Reference Number 2021-001 Criteria The Entity?s Uniform Guidance submission the OMB was due within thirty (30) days after the report date. Statement of Condition The OMB submission was not submitted before the due date. Cause The cause of the late OMB submission was management oversight due to change in management personnel positions. Effect or Potential Effect The Entity was not in compliance with the requirement to complete the filing of their Uniform Guidance submission to the OMB within thirty (30) days of the report date and therefore the Entity cannot be considered a low-risk auditee. Auditor Non-Compliance Code Z ? Other Questioned Costs There were no known questioned costs. Perspective The finding represents an isolated instance of management oversight due to change in personnel. Repeat Finding Yes Recommendations Auditor recommends that management more closely monitor the signing of the OMB submission to ensure timely completion. Views of Responsible Officials Actions Taken or Planned Auditee agrees with the finding. The finding was corrected by signing the OMB submission on 10/11/2022. The 2022 OMB filing will be signed upon the receipt of the finalized audit. Status of Corrective Action on Prior Findings Finding 2021-001 is cleared. The finding was corrected by signing the OMB submission on 10/11/2022.
Finding No. 2022-006 ? Unauthorized distribution Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size Net assets activity for the year ended August 31, 2022. Sample Size Information N/A Identification of Repeat Finding Reference Number N/A Criteria In accordance with the Entity?s regulatory agreement with HUD, only upon approval from HUD can the Entity distribute funds from the minimum capital investment account. Statement of Condition The Entity paid back $10,0000 from the minimum capital investment to Sponsor and did not have the proper HUD approval for the distribution. Cause The cause of the unauthorized distribution was management oversight due to change in management personnel positions. Effect or Potential Effect The Entity is in violation of the requirements of its regulatory agreement. Auditor Non-Compliance Code Z ? Other Questioned Costs There were no known questioned costs. Perspective The finding represents an isolated instance of management oversight due to change in personnel. Repeat Finding No Recommendations We recommend that management evaluate its process and implement policies to mitigate the chances of distributing funds from net assets without HUD approval. Views of Responsible Officials Auditee agrees with this finding and has taken steps to prevent this from occurring in the future. A new Executive Director has taken over the responsibility for distributing funds as well as oversight from the Board of Directors. Auditee is in the process of requesting HUD approval for the distribution. If accepted by HUD, this will clear this finding for the amount distributed during this fiscal year.
Finding No. 2022-001 ? Replacement Reserve Funding Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size 12 monthly payments Sample Size Information 12 monthly payments Identification of Repeat Finding Reference Number 2021-002 et seq. Criteria The regulatory agreement requires monthly payments of $1,640 to fund the replacement reserve. Statement of Condition The Entity was depositing the old required monthly payment rate of $1,562 and one monthly payment was not made to the replacement reserve during the year. Cause The cause of the incorrect deposit amount and missing payment was due to management oversight due to change in management personnel positions. Effect or Potential Effect The replacement reserve fund is underfunded by a total of $5,694. Auditor Non-Compliance Code N- Reserve for Replacements Deposits Questioned Costs There were no known questioned costs. Perspective The finding represents an instance of management oversight due to change in personnel. Repeat Finding Yes Recommendations Auditor recommends that the Entity fund the reserve immediately to make it current and create a better system of controls to ensure no further occurrences. Auditor notes deposit was made prior to issuance of the financial statements. No further action is required. Views of Responsible Officials Actions Taken or Planned - from Corrective Action Plan Auditee agrees with the finding and has made an additional deposit to the replacement reserve account in order to fully fund the reserve for replacements and has established a system of automatic monthly payments in order to properly fund the account going forward. Finding 2021-002 is cleared.
Finding No. 2022-002 ? Replacement Reserve Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size Replacement Reserve activity for the year ended August 31, 2022. Sample Size Information N/A Identification of Repeat Finding Reference Number 2021-003 Criteria In accordance with the Entity?s regulatory agreement with HUD, only upon approval from HUD can the Entity withdraw funds from the replacement reserve account. Statement of Condition The Entity withdrew $15,000 from the replacement reserve account without the approval of HUD. Cause Funds for unpaid vouchers for PRAC were withdrawn from replacement reserve and did not have the proper HUD approval for the withdrawals. Effect or Potential Effect The Entity is in violation of the requirements of its regulatory agreement. Auditor Non-Compliance Code A ? Unauthorized Withdrawals from the Replacement Reserve Account. Questioned Costs There were no known questioned costs. Perspective The finding is currently awaiting proper approval from the U.S. Department of Housing and Urban Development (?HUD?). Repeat Finding Yes Recommendations We recommend that management evaluate its process and implement policies to mitigate the chances of withdrawing funds from the replacement reserve without HUD approval. Views of Responsible Officials - from Corrective Action Plan Actions Taken or Planned Auditee agrees with this finding and has taken steps to prevent this from occurring in the future. A new Executive Director has taken over the responsibility for withdrawing funds as well as oversight from the Board of Directors. Auditee has been in discussion with HUD and will submit a letter with justification of withdrawals upon receipt of the notice of violation as requested by HUD. If accepted by HUD, this will clear this finding for the amount transferred during the fiscal year. Status of Corrective Action on Prior Findings Finding 2021-003 is cleared. A new Executive Director has taken over responsibility for withdrawing funds as well as oversight from the Board of Directors. A letter was submitted to HUD notifying them of the withdrawals by the previous director with a plan to correct. In addition to the letter, invoices were submitted to justify the transfers. HUD approval for the justification for the withdrawals was received on 2/21/2023 and 4/04/23. No amounts remain due to the account.
Finding No. 2022-003 ? Residual Receipts Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size Residual Receipts activity for the year ended August 31, 2022. Sample Size Information N/A Identification of Repeat Finding Reference Number 2021-004 Criteria In accordance with the Entity?s regulatory agreement with HUD, only upon approval from HUD can the Entity withdraw funds from the residual receipts account. Statement of Condition The Entity withdrew $127,309 from the residual receipts account without the approval of HUD. Cause Funds for repayment of minimum capital investment to Sponsor and operating expenses were withdrawn from residual receipts and did not have the proper HUD approval for the withdrawals. Effect or Potential Effect The Entity is in violation of the requirements of its regulatory agreement. Auditor Non-Compliance Code C ? Unauthorized Withdrawals from the Residual Receipts Account Questioned Costs There were no known questioned costs. Perspective The finding represents an instance of management oversight due to change in management personnel positions. Repeat Finding Yes Recommendations We recommend that management evaluate its process and implement policies to mitigate the chances of withdrawing funds from the residual receipts without HUD approval. Views of Responsible Officials -from corrective action plan. Actions Taken or Planned Auditee agrees with this finding and has taken steps to prevent this from occurring in the future. A new Executive Director has taken over the responsibility for withdrawing funds as well as oversight from the Board of Directors. Auditee has been in discussion with HUD and will submit a letter with justification of withdrawals upon receipt of the notice of violation as requested from HUD. If accepted by HUD, this will clear this finding for the amount transferred during this fiscal year.
Finding No. 2022-004 ? Timely Deposit of Surplus Cash Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size One (1) surplus cash deposit. Sample Size Information One (1) surplus cash deposit. Identification of Repeat Finding Reference Number 2017-001 et. seq. Criteria The regulatory agreement requires surplus cash payments to be deposited in the residual receipts reserve within 90 days of the fiscal year end. Statement of Condition The 2017 required surplus cash deposit was not made. Cause The cause of why the deposit was not made is due to management oversight due to change in management personnel positions. Effect or Potential Effect The requirement to deposit surplus cash within 90 days of the fiscal year end was not met. Auditor Non-Compliance Code B ? Failure to make required residual receipts deposits Questioned Costs There were no known questioned costs. Perspective The finding represents an instance of management oversight due to change in management personnel positions. Repeat Finding Yes Recommendations We recommend that management ensures the surplus cash deposit is done timely in the future. Views of Responsible Officials Actions Taken or Planned Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Going forward our focus will be to work with the auditor and owner to get the audits finalized earlier so adequate time is left for the deposits to be made. In instances where the final is not going to be issued and allow enough time, the deposit will be made based on the reviewed draft.
Finding No. 2022-005 ? Late Office of Management and Budget (OMB) Submission Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size One (1) OMB submission. Sample Size Information One (1) OMB submission. Identification of Repeat Finding Reference Number 2021-001 Criteria The Entity?s Uniform Guidance submission the OMB was due within thirty (30) days after the report date. Statement of Condition The OMB submission was not submitted before the due date. Cause The cause of the late OMB submission was management oversight due to change in management personnel positions. Effect or Potential Effect The Entity was not in compliance with the requirement to complete the filing of their Uniform Guidance submission to the OMB within thirty (30) days of the report date and therefore the Entity cannot be considered a low-risk auditee. Auditor Non-Compliance Code Z ? Other Questioned Costs There were no known questioned costs. Perspective The finding represents an isolated instance of management oversight due to change in personnel. Repeat Finding Yes Recommendations Auditor recommends that management more closely monitor the signing of the OMB submission to ensure timely completion. Views of Responsible Officials Actions Taken or Planned Auditee agrees with the finding. The finding was corrected by signing the OMB submission on 10/11/2022. The 2022 OMB filing will be signed upon the receipt of the finalized audit. Status of Corrective Action on Prior Findings Finding 2021-001 is cleared. The finding was corrected by signing the OMB submission on 10/11/2022.
Finding No. 2022-006 ? Unauthorized distribution Federal Assistance Listing Number Name of Federal Program or Cluster 14.157 Supportive Housing for the Elderly Information on the Universe Population Size Net assets activity for the year ended August 31, 2022. Sample Size Information N/A Identification of Repeat Finding Reference Number N/A Criteria In accordance with the Entity?s regulatory agreement with HUD, only upon approval from HUD can the Entity distribute funds from the minimum capital investment account. Statement of Condition The Entity paid back $10,0000 from the minimum capital investment to Sponsor and did not have the proper HUD approval for the distribution. Cause The cause of the unauthorized distribution was management oversight due to change in management personnel positions. Effect or Potential Effect The Entity is in violation of the requirements of its regulatory agreement. Auditor Non-Compliance Code Z ? Other Questioned Costs There were no known questioned costs. Perspective The finding represents an isolated instance of management oversight due to change in personnel. Repeat Finding No Recommendations We recommend that management evaluate its process and implement policies to mitigate the chances of distributing funds from net assets without HUD approval. Views of Responsible Officials Auditee agrees with this finding and has taken steps to prevent this from occurring in the future. A new Executive Director has taken over the responsibility for distributing funds as well as oversight from the Board of Directors. Auditee is in the process of requesting HUD approval for the distribution. If accepted by HUD, this will clear this finding for the amount distributed during this fiscal year.