Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.241, 14.267
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to Housing Opportunities for Persons with AIDS and the Continuum of Care Program during 2023 using allocations that lacked adequate support. During our testing we noted instances where employees did not track their actual time and effort for allocation to the grant, instances where the incorrect allocation rate was utilized, and/or allocations were not fully reviewed and approved.
• For Housing Opportunities for Persons with AIDS:
o 3 out of 60 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 1 out of 60 selections did not maintain a timesheet allocation.
o 3 out of 60 selections did not maintain documentation of employee and/or supervisor approval of timesheet allocations.
o 4 out of 60 selections had approved timesheet allocations that supported a higher rate than those utilized.
• For the Continuum of Care Program:
o 4 out of 83 selections did not maintain a timesheet allocation.
o 2 out of 83 selections had approved timesheet allocations that supported a lower rate than those utilized.
o 3 out of 83 selections did not match allocated timesheet hours to actual hours worked.
Cause: The Village did not have adequate policies/procedures in place to ensure timesheet allocations are obtained for all employees charging time to federal grants and that they are appropriately reviewed and incorporated into calculations for amounts charged to federal grants. The Village relied heavily on manual processes which are more prone to error and did not have an adequate review process to identify and correct calculation errors.
Effect or Potential Effect: Without adequate controls to detect calculation errors and ensure that costs allocated to federal programs are supported, the Village could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs:
Housing Opportunities for Persons with AIDS Known Questioned Costs: $881
Housing Opportunities for Persons with AIDS Likely Questioned Costs: $37,747
Continuum of Care Program Known Questioned Costs: $869
Continuum of Care Program Likely Questioned Costs: $144,388
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Total costs for the Continuum of Care Program in 2023 were $5,296,450. Any costs not adequately supported by approved timesheet allocations or in excess of supported allocations are considered questioned costs.
Identification as a Repeat Finding: 2022-010, 2022-017
Recommendation: We recommend implementing system improvements to reduce manual entry and establishing policies to review reimbursement calculations before submission. The Village should consistently obtain and retain timesheet allocation approvals from both employees and supervisors for each pay period requested for reimbursement. These records should be maintained until the grant is closed and required audits are completed.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development, Department of Health and Human Services
Federal Assistance Listing Numbers: 14.241, 93.224 & 93.527
Program: Housing Opportunities for Persons with AIDS, COVID-19 Housing Opportunities for Persons with AIDS, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: 558951, 570094, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated…”
Condition: For Housing Opportunities for Persons with AIDS, for 2 out of 60 nonpayroll selections, calculation errors were found in the initial costs that were then allocated to the grant. For the Health Center Program Cluster, for 17 out of 79 payroll selections, calculation errors were found in the initial costs that were then allocated to the grant. These errors resulted in differences between actual costs and the amounts charged to the program. This is an indication that controls are not functioning at a level to detect and correct all errors.
Cause: The Village relied heavily on manual processes which are more prone to errors and did not have an adequate review process to identify and correct calculation errors on initial cost calculations.
Effect or Potential Effect: Calculation errors may go undetected without adequate controls in place. The Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Housing Opportunities for Persons with AIDS in 2023 were $807,050. Payroll costs including fringe benefits for the Health Center Cluster in 2023 were $1,403,324.
Identification as a Repeat Finding: 2022-009
Recommendation: We recommend system improvements that require less manual entry and implement policies and procedures to review calculations and allocations of costs.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of implementing new processes and procedures to reduce manual errors.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development and Department of Health and Human Services
Federal Assistance Listing Numbers: 14.267, 93.224 & 93.527
Program: Continuum of Care Program, Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04, H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 2 CFR §200.430 Compensation – Personal Services:
“Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:
(i) Be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
(ii) Be incorporated into the official records of the non-Federal entity;
(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities;
(iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non Federal entity’s written policy;
(v) Comply with the established accounting policies and practices of the non Federal entity; and
(vi) [Reserved]
(vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
(viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;
(B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and
(C) The non-Federal entity’s system of internal controls includes processes to review after the fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
Condition: We noted that the Village allocated payroll expenditures to the Health Center Program Cluster and Continuum of Care Program during 2023 based on budget allocation rates or employees’ schedules. Attestations were completed at a later date, post grant close out, to support employee’s time allocated to the grant for reimbursement.
• For Health Center Program Cluster:
o 72 out of 79 selections did not have timely completion of attestations.
• For the Continuum of Care Program:
o 1 out of 56 selections did not have timely completion of attestations.
Cause: The Village did not have policies and procedures in place to timely prepare and complete timesheet attestations and reconcile to actual expenditures charged.
Effect or Potential Effect: Without adequate controls in place to ensure attestations were completed based on time worked, the Village could incorrectly charge expenditures to the Federal program, or not request appropriate reimbursement the Village is entitled to under the terms of the grant.
Questioned Costs: None reported.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Payroll costs including fringe benefits for the Health Center Program Cluster in 2023 were $1,403,324. Payroll costs including fringe benefits for the Continuum of Care Program in 2023 were $1,345,469.
Identification as a Repeat Finding: 2022-004.
Recommendation: We recommend that the Village implement policies and procedures to timely completed employee attestations and to ensure timely review for any necessary budget to actual adjustments.
Views of Responsible Officials: Management agrees with the finding. Management is updating their written procedures to ensure that allowable costs and cost principles comply with §200.430 as well as enhancements to the time entry system and allocation procedures to ensure timely completion.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per 24 CFR §578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.”
Condition: In accordance with 24 CFR §578.51(g), we noted that:
• 21 out of 60 rental payments tested did not have a comparable unit analysis conducted for move-in or increases in rent.
• 17 out of 60 rental payments did not have a comparable unit analysis completed in a timely manner prior to the tenant’s move-in or prior to increases in rent.
• 15 of the 43 rental payments that did have rent reasonableness performed did not have rent reasonableness analyzed in the past year.
• 4 out of 60 rental payments tested did not have documentation for amounts charged (such as lease agreements, rent increase letters, or invoices).
• 2 out of 60 rental payments tested had errors in the rent reasonableness forms.
Cause: The Village did not appropriately retain or produce documentation verifying that rent reasonableness was assessed prior to move-in or during changes to lease terms, as required by its policies. Additionally, not all supporting documentation for changes to lease terms was obtained or retained.
Effect or Potential Effect: The insufficient retention or creation of rent reasonableness forms and supporting documentation has led to ineffective operation of rent reasonableness controls, thereby not appropriately identifying rental amounts for the Village’s clients in need of rental assistance. Consequently, this deficiency could result in incorrect charges being applied to the Federal program.
Questioned Costs:
Known Questioned Costs: $33,686
Likely Questioned Costs: $910,698
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Questioned costs were determined as the amounts paid without supporting rent reasonableness documentation. The total costs subject to rent reasonableness amounted to $2,719,260. Of the questioned costs identified above, $2,702 of known and $65,525 of likely questioned costs relate to a subrecipient’s tenants, which the Village is still responsible for ensuring rent reasonableness is properly completed. The subrecipient processed rental assistance documentation for $204,409 of tenant payments.
Identification as a Repeat Finding: 2022-008
Recommendation: We recommend that the Village enhance existing policies to ensure rent reasonableness is performed on all rental assistance. In addition, we recommend management ensures determinations are performed prior to move-in or rent changes being charged, and documentation is maintained for both the rent amount and reasonableness of the rent. We further recommend a policy be enacted for reviewing rent reasonableness on a periodic basis (i.e. annually) for those tenants that have not had a change in rent during the period.
Views of Responsible Officials: Management agrees with the finding. Management is in the process of enhancing and enforcing existing policies and procedures as well as performing a comprehensive tenant record review.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Per 2 CFR §200.344(b): “Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.”
Condition: Expenditures were not liquidated within the required timeline after the end of the period of performance. We noted that 3 out of 94 samples selected for testing were not liquidated by the end of the grant period for grants with end dates during 2023. As such reimbursements were not liquidated in accordance with §200.344.
Cause: The Village did not have policies and procedures in place to ensure that payments were made within 120 calendar days after the end of the period of performance.
Effect or Potential Effect: Without adequate controls in place to timely liquidate expenditures, the Village is not in compliance with §200.344.
Questioned Costs:
Known Questioned Costs Continuum of Care: $2,616
Likely Questioned Costs Continuum of Care: $435,898
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that costs are liquidated timely and policies and procedures are updated to ensure all obligations are liquidated within 120 days after the end of the period of performance.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding liquidation of obligations to ensure obligations are liquidated within 120 days after the end of the period of performance.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care Program
Award/Pass-Through Entity Identifying Numbers: CA0802L9D012113, CA0802L9D012214, CA1348L9D012107, CA1348L9D012208, CA1510L9D012106, CA1510LD012207, CA1883L9D012102, CA1883L9D012203, HHI-23-03, HHI-24-09, HHI-23-13, HHI-24-04
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: The Village allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that 1 of the 60 samples selected for testing within the Continuum of Care Program, were incurred prior to the start of the applicable funding periods and were not approved in accordance with §200.308.
Cause: The Village did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, the Village could incorrectly charge expenditures to the federal programs.
Questioned Costs: None above the $25,000 reporting threshold.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. Total costs under the program in 2023 were $5,296,450.
Identification as a Repeat Finding: 2022-006.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with this finding. Management is updating written procedures regarding period of performance to ensure requests of expenditures are within the proper period.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.
Federal Agencies: Department of Health and Human Services
Federal Assistance Listing Numbers: 93.224 & 93.527
Program: Health Center Program Cluster, COVID-19 Health Center Program Cluster
Award/Pass-Through Entity Identifying Numbers: H80CS10606-15-01, H80CS10606-16-00, 21H8FCS40355C6, H8GCS48224
Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted.
Condition: For two out of four reports selected for testing, appropriate documentation was not available to evidence review of the report prior to submission.
Cause: While the Village has a policy in place that requires review of reports, proper documentation to support the policy was not available.
Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Village does not have the documentation required regarding review/approval of the performance reports.
Questioned Costs: None.
Context: This is a condition identified per review of the Village’s compliance with specified requirements not using a statistically valid sample. There were four reports submitted during the fiscal year.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Village implement controls to ensure proper documentation of review and approval of performance reports.
Views of Responsible Officials: Management agrees with this finding. Management is updating their procedures to ensure documentation for review and approval of reports is prepared and maintained for future reports.