Audit 22860

FY End
2022-12-31
Total Expended
$1.87M
Findings
14
Programs
12
Organization: Brighter Tomorrows, Inc. (NY)
Year: 2022 Accepted: 2023-10-01

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
22601 2022-001 Significant Deficiency Yes P
22602 2022-001 Significant Deficiency Yes P
22603 2022-001 Significant Deficiency Yes P
22604 2022-001 Significant Deficiency Yes P
22605 2022-001 Significant Deficiency Yes P
22606 2022-001 Significant Deficiency - P
22607 2022-002 Significant Deficiency - N
599043 2022-001 Significant Deficiency Yes P
599044 2022-001 Significant Deficiency Yes P
599045 2022-001 Significant Deficiency Yes P
599046 2022-001 Significant Deficiency Yes P
599047 2022-001 Significant Deficiency Yes P
599048 2022-001 Significant Deficiency - P
599049 2022-002 Significant Deficiency - N

Programs

Contacts

Name Title Type
XWSKBXQ9CN17 Dolores Kordon Auditee
6313951800 Jill S. Sanders, CPA Auditor
No contacts on file

Notes to SEFA

Title: SUBRECIPIENTS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or limited as to reimbursement. Matching costs (the Organizations share of certain program costs) are not included in the reported expenditures. Pass-through numbers are presented where available. The amounts reported as federal expenditures were obtained from the federal financial reports for the applicable program and periods. The amounts reported in these reports are prepared from records maintained for each program, which are reconciled with the Organizations financial reporting system. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. No amounts were provided to subrecipients.
Title: OTHER DISCLOSURES Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or limited as to reimbursement. Matching costs (the Organizations share of certain program costs) are not included in the reported expenditures. Pass-through numbers are presented where available. The amounts reported as federal expenditures were obtained from the federal financial reports for the applicable program and periods. The amounts reported in these reports are prepared from records maintained for each program, which are reconciled with the Organizations financial reporting system. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. No insurance is carried specifically to cover equipment purchased with federal funds. Any equipment purchased with federal funds has only a nominal value, and is covered by the Organizations casualty insurance policies. There were no loans or loan guarantees outstanding at year end.

Finding Details

2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-002. Special Tests and Provisions United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: Where 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 relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units, and the portion of rents paid with grant funds may not exceed HUD-determined fair market rents. Condition: In our testing, there were instances in which comparable rents for the area were not documented and maintained in tenant files, to provide documentation of compliance with the criteria. Cause: The Organization did not have an adequate control in place for the review by a supervisor of every tenant file to ensure that the permanent documentation to conclude that reasonable rent was being charged. The Organizations has a control in place, instead, which required review of a selection of tenant files. Effect: The Organization could potentially not be in compliance with the requirement to ensure that grant funds to pay rent were used for reasonable rent in relation to comparable rent in the area. Questioned Costs: None reported. Context: During a review of tenant files, it was noted that documentation regarding comparable rentals was not included within the file. The Organization did maintain for reference the FY 2022 and FY 2023 Nassau-Suffolk, NY HUD Metro FMR Areas FMRs for All Bedroom Sizes, and also used this to assess reasonable rent. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures for supervisor review of documents and approval of tenant files to ensure all proper documentation to support reasonable rent is maintained. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will put proper procedures in place to ensure written documentation is maintained in tenant files, to support that the grant funds to pay rent were used for reasonable rent in relation to comparable rent in the area.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.
2022-002. Special Tests and Provisions United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: Where 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 relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units, and the portion of rents paid with grant funds may not exceed HUD-determined fair market rents. Condition: In our testing, there were instances in which comparable rents for the area were not documented and maintained in tenant files, to provide documentation of compliance with the criteria. Cause: The Organization did not have an adequate control in place for the review by a supervisor of every tenant file to ensure that the permanent documentation to conclude that reasonable rent was being charged. The Organizations has a control in place, instead, which required review of a selection of tenant files. Effect: The Organization could potentially not be in compliance with the requirement to ensure that grant funds to pay rent were used for reasonable rent in relation to comparable rent in the area. Questioned Costs: None reported. Context: During a review of tenant files, it was noted that documentation regarding comparable rentals was not included within the file. The Organization did maintain for reference the FY 2022 and FY 2023 Nassau-Suffolk, NY HUD Metro FMR Areas FMRs for All Bedroom Sizes, and also used this to assess reasonable rent. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures for supervisor review of documents and approval of tenant files to ensure all proper documentation to support reasonable rent is maintained. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will put proper procedures in place to ensure written documentation is maintained in tenant files, to support that the grant funds to pay rent were used for reasonable rent in relation to comparable rent in the area.