U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Matching, Level of Effort, Earmarking
Significant Deficiency in Internal Control over Compliance
Criteria: No more than 10 percent of any grant awarded may be used for paying the costs of administering the assistance. Administrative costs include the costs associated with general management, oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA costs (24 CFR section 578.59).
Condition: During out testing, we identified differences in the amounts in the grant billing worksheets and the amounts recorded in the general ledger for administrative expenses.
Cause: The Organization has experienced significant staff turnover and the Organization’s controls are currently not adequately designed and operating.
Effect: The amounts reported in the billing worksheets didn’t agree to the amounts recorded in the general ledger. For administrative expenses.
Questioned Costs: None reported.
Context/Sampling: Not applicable.
Repeat Finding from Prior Year: No
Recommendation: The Organization should implement internal controls to ensure the amounts reported in the grant billing worksheets agree to the general ledger.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.