Audit 322823

FY End
2023-12-31
Total Expended
$3.33M
Findings
20
Programs
11
Organization: Lutheran Metropolitan Ministry (OH)
Year: 2023 Accepted: 2024-09-30
Auditor: Rsm US LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
499888 2023-002 Significant Deficiency - I
499889 2023-002 Significant Deficiency - I
499890 2023-002 Significant Deficiency - I
499891 2023-002 Significant Deficiency - I
499892 2023-002 Significant Deficiency - I
499893 2023-003 Significant Deficiency - AB
499894 2023-003 Significant Deficiency - AB
499895 2023-003 Significant Deficiency - AB
499896 2023-003 Significant Deficiency - AB
499897 2023-003 Significant Deficiency - AB
1076330 2023-002 Significant Deficiency - I
1076331 2023-002 Significant Deficiency - I
1076332 2023-002 Significant Deficiency - I
1076333 2023-002 Significant Deficiency - I
1076334 2023-002 Significant Deficiency - I
1076335 2023-003 Significant Deficiency - AB
1076336 2023-003 Significant Deficiency - AB
1076337 2023-003 Significant Deficiency - AB
1076338 2023-003 Significant Deficiency - AB
1076339 2023-003 Significant Deficiency - AB

Contacts

Name Title Type
W419QMGP9919 Sue Cyncynatus Auditee
2166584638 David Andrews Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Organization has elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of Lutheran Metropolitan Ministry and its controlled entities (the Organization) under programs of the federal government for the year ended December 31, 2023. The information in this Schedule is presented in acordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Organization, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Organization.
Title: Note 2. Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Organization has elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement.
Title: Note 3. Indirect Cost Rate Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Organization has elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The Organization has elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance.

Finding Details

Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk of procuring with vendors that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-003: Lack of sufficient documentation to evidence controls over Allowability of Activities and Allowable Costs Identification of the federal programs: Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative Assistance Listing Numbers: 14.231, 16.812 Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1 Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence the review and approval of certain costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative. Cause: Lutheran Metropolitan Ministry’s processes and controls established for review and approval of costs charged to the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative did not allow for the retention of documentation to evidence such review and approval was completed for certain costs tested.  Effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide evidence for review and approval for four out of 40 non-payroll costs tested. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all costs charged to federal programs have sufficient evidence that proper review was performed. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.