Allowable and Unallowable Costs
Assistance Listing No.: 16.567 Crime Victims Compensation
Condition: The Organization did not provide supporting documentation for certain expenditures.
Criteria: The expenditures were necessary and reasonable for performance of the federal award and
allowable costs under grants and cooperative agreements are contained in 2 CFR sections 200
subpart E.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the
expenditure took place during the grant period resulting in a questioned question cost of
$12,739 for 16.567.
Cause: The Organization was unable to locate supporting documentation.
Effect: The Organization is at risk of reduction of federal aid.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to
ensure the reported information is accurate.
Repeat Finding: This is not a repeat finding.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management
develop a method to track federal grant funds and the use of those funds and reconcile both to
the general ledger.
Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.
Allowable and Unallowable Costs
Assistance Listing No.: 16.567 Crime Victims Compensation
Condition: The Organization did not provide supporting documentation for certain expenditures.
Criteria: The expenditures were necessary and reasonable for performance of the federal award and
allowable costs under grants and cooperative agreements are contained in 2 CFR sections 200
subpart E.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the
expenditure took place during the grant period resulting in a questioned question cost of
$12,739 for 16.567.
Cause: The Organization was unable to locate supporting documentation.
Effect: The Organization is at risk of reduction of federal aid.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to
ensure the reported information is accurate.
Repeat Finding: This is not a repeat finding.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management
develop a method to track federal grant funds and the use of those funds and reconcile both to
the general ledger.
Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-001: Special Test and Provisions – Reasonable Rental Rates:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The Organization was unable to provide the HUD rent reasonableness checklist and certifications as well as comparable rent payments for the items selected for testing.
Criteria: Where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space (24 CFR section 578.49(b)(1)). 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. Grant funds in an amount up to one month’s rent may be used to pay the non-recipient landlord for any damages to leased units by homeless participants (24 CFR sections 578.49(b)(2) and 578.51(g) and (j)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the amount paid for rent could be excessive.
Cause: The Organization did not have good controls on maintaining the checklist and obtaining the rent monthly comparable from the landlord.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management retain all checklist and documentation as needed. We also recommend that management obtain and keep the comparable rent cost from the landlord on file.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-001: Special Test and Provisions – Reasonable Rental Rates:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The Organization was unable to provide the HUD rent reasonableness checklist and certifications as well as comparable rent payments for the items selected for testing.
Criteria: Where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space (24 CFR section 578.49(b)(1)). 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. Grant funds in an amount up to one month’s rent may be used to pay the non-recipient landlord for any damages to leased units by homeless participants (24 CFR sections 578.49(b)(2) and 578.51(g) and (j)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the amount paid for rent could be excessive.
Cause: The Organization did not have good controls on maintaining the checklist and obtaining the rent monthly comparable from the landlord.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management retain all checklist and documentation as needed. We also recommend that management obtain and keep the comparable rent cost from the landlord on file.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-001: Special Test and Provisions – Reasonable Rental Rates:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The Organization was unable to provide the HUD rent reasonableness checklist and certifications as well as comparable rent payments for the items selected for testing.
Criteria: Where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space (24 CFR section 578.49(b)(1)). 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. Grant funds in an amount up to one month’s rent may be used to pay the non-recipient landlord for any damages to leased units by homeless participants (24 CFR sections 578.49(b)(2) and 578.51(g) and (j)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the amount paid for rent could be excessive.
Cause: The Organization did not have good controls on maintaining the checklist and obtaining the rent monthly comparable from the landlord.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management retain all checklist and documentation as needed. We also recommend that management obtain and keep the comparable rent cost from the landlord on file.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-001: Special Test and Provisions – Reasonable Rental Rates:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The Organization was unable to provide the HUD rent reasonableness checklist and certifications as well as comparable rent payments for the items selected for testing.
Criteria: Where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space (24 CFR section 578.49(b)(1)). 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. Grant funds in an amount up to one month’s rent may be used to pay the non-recipient landlord for any damages to leased units by homeless participants (24 CFR sections 578.49(b)(2) and 578.51(g) and (j)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the amount paid for rent could be excessive.
Cause: The Organization did not have good controls on maintaining the checklist and obtaining the rent monthly comparable from the landlord.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management retain all checklist and documentation as needed. We also recommend that management obtain and keep the comparable rent cost from the landlord on file.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-002: Matching, Level of Effort, Earmarking:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the matching requirement.
Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the Organizational will not meet the percent matching requirements since there is no formal set of controls over the requirement.
Cause: The Organization did not have good controls on ensuring the matching requirement was met.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a set of controls to ensure that they are meeting 25% match.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-002: Matching, Level of Effort, Earmarking:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the matching requirement.
Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the Organizational will not meet the percent matching requirements since there is no formal set of controls over the requirement.
Cause: The Organization did not have good controls on ensuring the matching requirement was met.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a set of controls to ensure that they are meeting 25% match.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-002: Matching, Level of Effort, Earmarking:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the matching requirement.
Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the Organizational will not meet the percent matching requirements since there is no formal set of controls over the requirement.
Cause: The Organization did not have good controls on ensuring the matching requirement was met.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a set of controls to ensure that they are meeting 25% match.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-002: Matching, Level of Effort, Earmarking:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the matching requirement.
Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the Organizational will not meet the percent matching requirements since there is no formal set of controls over the requirement.
Cause: The Organization did not have good controls on ensuring the matching requirement was met.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a set of controls to ensure that they are meeting 25% match.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing.
Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267.
Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation.
Effect: The Organization could have grant expenditures outside the grant period.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing.
Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267.
Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation.
Effect: The Organization could have grant expenditures outside the grant period.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing.
Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267.
Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation.
Effect: The Organization could have grant expenditures outside the grant period.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing.
Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267.
Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation.
Effect: The Organization could have grant expenditures outside the grant period.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Allowable and Unallowable Costs
Assistance Listing No.: 16.567 Crime Victims Compensation
Condition: The Organization did not provide supporting documentation for certain expenditures.
Criteria: The expenditures were necessary and reasonable for performance of the federal award and
allowable costs under grants and cooperative agreements are contained in 2 CFR sections 200
subpart E.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the
expenditure took place during the grant period resulting in a questioned question cost of
$12,739 for 16.567.
Cause: The Organization was unable to locate supporting documentation.
Effect: The Organization is at risk of reduction of federal aid.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to
ensure the reported information is accurate.
Repeat Finding: This is not a repeat finding.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management
develop a method to track federal grant funds and the use of those funds and reconcile both to
the general ledger.
Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.
Allowable and Unallowable Costs
Assistance Listing No.: 16.567 Crime Victims Compensation
Condition: The Organization did not provide supporting documentation for certain expenditures.
Criteria: The expenditures were necessary and reasonable for performance of the federal award and
allowable costs under grants and cooperative agreements are contained in 2 CFR sections 200
subpart E.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the
expenditure took place during the grant period resulting in a questioned question cost of
$12,739 for 16.567.
Cause: The Organization was unable to locate supporting documentation.
Effect: The Organization is at risk of reduction of federal aid.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to
ensure the reported information is accurate.
Repeat Finding: This is not a repeat finding.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management
develop a method to track federal grant funds and the use of those funds and reconcile both to
the general ledger.
Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-005: Reporting
Federal Program: Assistance Listing No.: 14.267 Continuum of Care Program (“CoC”) & 93.558 Temporary Assistance for Needy Families (TANF)
Condition: The Organization did not prepare a complete Schedule of Expenditures of Federal Awards that
was able to be verified and tie out to trial balance.
Criteria: The Schedule of Expenditures of Federal Awards ("SEFA") is required under federal regulations to be prepared by the Auditee by funding organizations when spending $750,000 or more in federal funds.
Questioned Costs: There are no questioned costs.
Cause: The Organization did not have sufficient controls over the tracking of federal and state
expenditures and reconciled to the general ledger.
Effect: The Organization could have expenditures reported on the SEFA that should not be or ones that should have been reported but were not reported on the SEFA.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a method to track federal grant funds and the use of those funds and reconcile both to the general ledger.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure that reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-001: Special Test and Provisions – Reasonable Rental Rates:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The Organization was unable to provide the HUD rent reasonableness checklist and certifications as well as comparable rent payments for the items selected for testing.
Criteria: Where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space (24 CFR section 578.49(b)(1)). 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. Grant funds in an amount up to one month’s rent may be used to pay the non-recipient landlord for any damages to leased units by homeless participants (24 CFR sections 578.49(b)(2) and 578.51(g) and (j)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the amount paid for rent could be excessive.
Cause: The Organization did not have good controls on maintaining the checklist and obtaining the rent monthly comparable from the landlord.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management retain all checklist and documentation as needed. We also recommend that management obtain and keep the comparable rent cost from the landlord on file.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-001: Special Test and Provisions – Reasonable Rental Rates:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The Organization was unable to provide the HUD rent reasonableness checklist and certifications as well as comparable rent payments for the items selected for testing.
Criteria: Where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space (24 CFR section 578.49(b)(1)). 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. Grant funds in an amount up to one month’s rent may be used to pay the non-recipient landlord for any damages to leased units by homeless participants (24 CFR sections 578.49(b)(2) and 578.51(g) and (j)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the amount paid for rent could be excessive.
Cause: The Organization did not have good controls on maintaining the checklist and obtaining the rent monthly comparable from the landlord.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management retain all checklist and documentation as needed. We also recommend that management obtain and keep the comparable rent cost from the landlord on file.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-001: Special Test and Provisions – Reasonable Rental Rates:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The Organization was unable to provide the HUD rent reasonableness checklist and certifications as well as comparable rent payments for the items selected for testing.
Criteria: Where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space (24 CFR section 578.49(b)(1)). 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. Grant funds in an amount up to one month’s rent may be used to pay the non-recipient landlord for any damages to leased units by homeless participants (24 CFR sections 578.49(b)(2) and 578.51(g) and (j)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the amount paid for rent could be excessive.
Cause: The Organization did not have good controls on maintaining the checklist and obtaining the rent monthly comparable from the landlord.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management retain all checklist and documentation as needed. We also recommend that management obtain and keep the comparable rent cost from the landlord on file.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-001: Special Test and Provisions – Reasonable Rental Rates:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The Organization was unable to provide the HUD rent reasonableness checklist and certifications as well as comparable rent payments for the items selected for testing.
Criteria: Where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space (24 CFR section 578.49(b)(1)). 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. Grant funds in an amount up to one month’s rent may be used to pay the non-recipient landlord for any damages to leased units by homeless participants (24 CFR sections 578.49(b)(2) and 578.51(g) and (j)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the amount paid for rent could be excessive.
Cause: The Organization did not have good controls on maintaining the checklist and obtaining the rent monthly comparable from the landlord.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management retain all checklist and documentation as needed. We also recommend that management obtain and keep the comparable rent cost from the landlord on file.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-002: Matching, Level of Effort, Earmarking:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the matching requirement.
Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the Organizational will not meet the percent matching requirements since there is no formal set of controls over the requirement.
Cause: The Organization did not have good controls on ensuring the matching requirement was met.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a set of controls to ensure that they are meeting 25% match.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-002: Matching, Level of Effort, Earmarking:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the matching requirement.
Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the Organizational will not meet the percent matching requirements since there is no formal set of controls over the requirement.
Cause: The Organization did not have good controls on ensuring the matching requirement was met.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a set of controls to ensure that they are meeting 25% match.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-002: Matching, Level of Effort, Earmarking:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the matching requirement.
Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the Organizational will not meet the percent matching requirements since there is no formal set of controls over the requirement.
Cause: The Organization did not have good controls on ensuring the matching requirement was met.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a set of controls to ensure that they are meeting 25% match.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-002: Matching, Level of Effort, Earmarking:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the matching requirement.
Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)).
Questioned Costs: There are no questioned costs.
Effect: It is more likely that the Organizational will not meet the percent matching requirements since there is no formal set of controls over the requirement.
Cause: The Organization did not have good controls on ensuring the matching requirement was met.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management develop a set of controls to ensure that they are meeting 25% match.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure no issues arise.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing.
Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267.
Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation.
Effect: The Organization could have grant expenditures outside the grant period.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing.
Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267.
Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation.
Effect: The Organization could have grant expenditures outside the grant period.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing.
Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267.
Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation.
Effect: The Organization could have grant expenditures outside the grant period.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-003: Period of Performance:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the period of performance for six items selected for testing.
Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense was incurred during the grant period resulting in a questioned cost of $2,699 for 14.267.
Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over and being unable to locate documentation.
Effect: The Organization could have grant expenditures outside the grant period.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate the period of performance.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to ensure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.
Formerly 2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation
Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567
Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate.
Repeat: This is a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.