Audit 323358

Significant Deficiencies 2023-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Under the Uniform Guidance, federal award recipients must maintain updated written documentation of internal control policies and procedures, which include a procurement policy that complies with 2 CFR 200.317-327.Additionally, under Uniform Guidance, federal award recipients must maintain a written record retention policy that complies with 24 CFR 578.103(c). Condition: The Organization did not have written policies referencing these requirements. Cause: The Organization’s current written policies and procedures was to be updated during the year, but personnel changes impacted the timetable for completing this task. Potential Effect: Not having the updated policies and procedures could weaken the internal controls over expenditures charged to the federal award. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding, related to the 2022 audit, finding #2022- 001. Recommendation: The Organization should update their policies and procedures manual to ensure compliance with the procurement requirements at 2 CFR 200.317-327, and the impact of 24 CFR 578.103(c). Views of Responsible Officials of Auditee: The Organization agrees with the finding and will update the written policies and procedures to comply with the Uniform Guidance requirements.

2023-002. Allowable Costs/Cost Principles United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensationpersonal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should 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. Condition: The Organization charged costs for staff time without source documentation that complied with Uniform Guidance. Cause: The Organization used time records which did not clearly differentiate between the activities conducted and the hours worked to support compensation supported by each federal award and nonfederal awards. Potential Effect: Reimbursement for compensation under federal awards without time records, such as personnel activity equivalent reports, might result in the incorrect payment amount of payroll expenses. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding related to the 2021 audit, finding #2021-002, related to the Crime Victim Assistance grant. Recommendation: The Organization should maintain Personnel Activity Reports (PAR) or equivalent documentation. This reporting of time will allow each employee to accurately reflect the time work is performed, for compensation which is funded by a federal award. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will modify procedures to reflect actual time worked by employee on PAR equivalent documentation, which will serve as support for personnel expenses funded by a federal award.

Significant Deficiencies 2023-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Under the Uniform Guidance, federal award recipients must maintain updated written documentation of internal control policies and procedures, which include a procurement policy that complies with 2 CFR 200.317-327.Additionally, under Uniform Guidance, federal award recipients must maintain a written record retention policy that complies with 24 CFR 578.103(c). Condition: The Organization did not have written policies referencing these requirements. Cause: The Organization’s current written policies and procedures was to be updated during the year, but personnel changes impacted the timetable for completing this task. Potential Effect: Not having the updated policies and procedures could weaken the internal controls over expenditures charged to the federal award. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding, related to the 2022 audit, finding #2022- 001. Recommendation: The Organization should update their policies and procedures manual to ensure compliance with the procurement requirements at 2 CFR 200.317-327, and the impact of 24 CFR 578.103(c). Views of Responsible Officials of Auditee: The Organization agrees with the finding and will update the written policies and procedures to comply with the Uniform Guidance requirements.

2023-002. Allowable Costs/Cost Principles United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensationpersonal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should 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. Condition: The Organization charged costs for staff time without source documentation that complied with Uniform Guidance. Cause: The Organization used time records which did not clearly differentiate between the activities conducted and the hours worked to support compensation supported by each federal award and nonfederal awards. Potential Effect: Reimbursement for compensation under federal awards without time records, such as personnel activity equivalent reports, might result in the incorrect payment amount of payroll expenses. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding related to the 2021 audit, finding #2021-002, related to the Crime Victim Assistance grant. Recommendation: The Organization should maintain Personnel Activity Reports (PAR) or equivalent documentation. This reporting of time will allow each employee to accurately reflect the time work is performed, for compensation which is funded by a federal award. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will modify procedures to reflect actual time worked by employee on PAR equivalent documentation, which will serve as support for personnel expenses funded by a federal award.

2023-003. Written Intake Procedures United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: 24 CFR 576.500(b) of the Uniform Guidance requires the Organization to maintain and follow written intake procedures to ensure compliance with the homeless definition in 24 CFR 576.2. The intake procedures must require documentation verifying homeless status, and must follow the order of priority for obtaining evidence of homelessness; third-party documentation first, intake worker observations second, and certification from the person seeking assistance third. Condition: The Organization was unable to provide written policies and procedures with respect to intake documentation and the calculation of rent. Cause: Staffing constraints limited the Organization’s ability to complete policies and procedures to comply with the requirements for this program. Effect: Not having documented the intake policies and procedures and rent calculations, could result in incorrect calculations of rent reimbursements. Questioned Costs: None reported. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should complete the written policies and procedures to comply with the written intake provisions under Uniform Guidance, as well as rent calculations. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will maintain the written intake policies and procedures as well as rent calculations.

2023-004. Special Tests and Provisions United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units, and the portion of rents paid with grant funds may not exceed HUDdetermined fair market rents. Condition: There were instances in which comparable rents for the area were not documented and maintained in tenant files. Cause: The Organization did not have an adequate control in place for the review by a supervisor of every tenant file to ensure that permanent documentation to conclude that reasonable rent being charged was maintained, rather because of staffing constraints, a review of a selection of tenant files was performed for compliance with this criteria. Potential Effect: The Organization may not be in compliance that grant funds to pay rent were used for reasonable rent in relation to comparable rent in the area. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding related to the 2022 audit, finding #2022-002. Recommendation: The Organization should implement procedures for supervisory review of documentation within all tenant files to ensure reasonable rent criteria is demonstrated. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will ensure written documentation is maintained in tenant files, to support that the grant funds to pay rent were used for reasonable rent in relation to comparable rents in the area.

2023-005. Match Source Documentation United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: 24 CFR 578.73(a) of the Uniform Guidance specifies the Organization’s match requirements. 24 CFR 578.103(a)(11) requires the Organization to maintain records of the source and use of contributions made to satisfy the match requirement. The records must indicate the grant and fiscal year for which each matching contribution is counted, how the value placed on third party-in-kind contributions was derived; and to the extent feasible, volunteer services should be supported by the same methods that the organization uses to support the allocation of regular personnel costs. Condition: Source documentation was not maintained to support costs applied to the match. Cause: Personnel changes limited the Organization’s ability to maintain a list of funds expended which were attributed to meeting the match requirements. Potential Effect: Without documentation of funds expended attributed to meeting the match requirement, the Organization could be receiving reimbursements that were for improper amounts. Questioned Costs: The Organization’s 25% match was calculated at $135,900. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should maintain an accounting for all funds expended attributed to meeting the match requirement, as well as the source documentation. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will implement procedures to ensure accounting for funds expended, as well as source documentation, is maintained for costs attributed to meeting the match requirement.

2023-006. Allowable Costs/Cost Principles United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: 24 CFR 578.99(e) of the Uniform Guidance states the requirements of administrative requirements, cost principles, and audit requirements for Federal awards under 2 CFR 200. Condition: An allocation for costs within the administrative components of the budget was not maintained. A percentage of the total administrative budget was requested for reimbursement based on an estimate of costs expended. Cause: Personnel changes limited the Organization’s ability to properly contemporaneously track the allocation of the administrative expense. Potential Effect: Not having a documented allocation of the administrative component of the budget could result in the Organization reporting and receiving reimbursement for the incorrect amount of related costs. Questioned Costs: The administrative budget is $71,544 Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures to ensure that administrative related charges to the program are documented by an allocation calculation. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will implement procedures to ensure an allocation for administrative related expenses is performed and documented.

Significant Deficiencies 2023-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Under the Uniform Guidance, federal award recipients must maintain updated written documentation of internal control policies and procedures, which include a procurement policy that complies with 2 CFR 200.317-327.Additionally, under Uniform Guidance, federal award recipients must maintain a written record retention policy that complies with 24 CFR 578.103(c). Condition: The Organization did not have written policies referencing these requirements. Cause: The Organization’s current written policies and procedures was to be updated during the year, but personnel changes impacted the timetable for completing this task. Potential Effect: Not having the updated policies and procedures could weaken the internal controls over expenditures charged to the federal award. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding, related to the 2022 audit, finding #2022- 001. Recommendation: The Organization should update their policies and procedures manual to ensure compliance with the procurement requirements at 2 CFR 200.317-327, and the impact of 24 CFR 578.103(c). Views of Responsible Officials of Auditee: The Organization agrees with the finding and will update the written policies and procedures to comply with the Uniform Guidance requirements.

2023-002. Allowable Costs/Cost Principles United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensationpersonal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should 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. Condition: The Organization charged costs for staff time without source documentation that complied with Uniform Guidance. Cause: The Organization used time records which did not clearly differentiate between the activities conducted and the hours worked to support compensation supported by each federal award and nonfederal awards. Potential Effect: Reimbursement for compensation under federal awards without time records, such as personnel activity equivalent reports, might result in the incorrect payment amount of payroll expenses. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding related to the 2021 audit, finding #2021-002, related to the Crime Victim Assistance grant. Recommendation: The Organization should maintain Personnel Activity Reports (PAR) or equivalent documentation. This reporting of time will allow each employee to accurately reflect the time work is performed, for compensation which is funded by a federal award. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will modify procedures to reflect actual time worked by employee on PAR equivalent documentation, which will serve as support for personnel expenses funded by a federal award.

Significant Deficiencies 2023-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Under the Uniform Guidance, federal award recipients must maintain updated written documentation of internal control policies and procedures, which include a procurement policy that complies with 2 CFR 200.317-327.Additionally, under Uniform Guidance, federal award recipients must maintain a written record retention policy that complies with 24 CFR 578.103(c). Condition: The Organization did not have written policies referencing these requirements. Cause: The Organization’s current written policies and procedures was to be updated during the year, but personnel changes impacted the timetable for completing this task. Potential Effect: Not having the updated policies and procedures could weaken the internal controls over expenditures charged to the federal award. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding, related to the 2022 audit, finding #2022- 001. Recommendation: The Organization should update their policies and procedures manual to ensure compliance with the procurement requirements at 2 CFR 200.317-327, and the impact of 24 CFR 578.103(c). Views of Responsible Officials of Auditee: The Organization agrees with the finding and will update the written policies and procedures to comply with the Uniform Guidance requirements.

2023-002. Allowable Costs/Cost Principles United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensationpersonal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should 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. Condition: The Organization charged costs for staff time without source documentation that complied with Uniform Guidance. Cause: The Organization used time records which did not clearly differentiate between the activities conducted and the hours worked to support compensation supported by each federal award and nonfederal awards. Potential Effect: Reimbursement for compensation under federal awards without time records, such as personnel activity equivalent reports, might result in the incorrect payment amount of payroll expenses. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding related to the 2021 audit, finding #2021-002, related to the Crime Victim Assistance grant. Recommendation: The Organization should maintain Personnel Activity Reports (PAR) or equivalent documentation. This reporting of time will allow each employee to accurately reflect the time work is performed, for compensation which is funded by a federal award. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will modify procedures to reflect actual time worked by employee on PAR equivalent documentation, which will serve as support for personnel expenses funded by a federal award.

2023-003. Written Intake Procedures United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: 24 CFR 576.500(b) of the Uniform Guidance requires the Organization to maintain and follow written intake procedures to ensure compliance with the homeless definition in 24 CFR 576.2. The intake procedures must require documentation verifying homeless status, and must follow the order of priority for obtaining evidence of homelessness; third-party documentation first, intake worker observations second, and certification from the person seeking assistance third. Condition: The Organization was unable to provide written policies and procedures with respect to intake documentation and the calculation of rent. Cause: Staffing constraints limited the Organization’s ability to complete policies and procedures to comply with the requirements for this program. Effect: Not having documented the intake policies and procedures and rent calculations, could result in incorrect calculations of rent reimbursements. Questioned Costs: None reported. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should complete the written policies and procedures to comply with the written intake provisions under Uniform Guidance, as well as rent calculations. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will maintain the written intake policies and procedures as well as rent calculations.

2023-004. Special Tests and Provisions United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units, and the portion of rents paid with grant funds may not exceed HUDdetermined fair market rents. Condition: There were instances in which comparable rents for the area were not documented and maintained in tenant files. Cause: The Organization did not have an adequate control in place for the review by a supervisor of every tenant file to ensure that permanent documentation to conclude that reasonable rent being charged was maintained, rather because of staffing constraints, a review of a selection of tenant files was performed for compliance with this criteria. Potential Effect: The Organization may not be in compliance that grant funds to pay rent were used for reasonable rent in relation to comparable rent in the area. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding related to the 2022 audit, finding #2022-002. Recommendation: The Organization should implement procedures for supervisory review of documentation within all tenant files to ensure reasonable rent criteria is demonstrated. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will ensure written documentation is maintained in tenant files, to support that the grant funds to pay rent were used for reasonable rent in relation to comparable rents in the area.

2023-005. Match Source Documentation United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: 24 CFR 578.73(a) of the Uniform Guidance specifies the Organization’s match requirements. 24 CFR 578.103(a)(11) requires the Organization to maintain records of the source and use of contributions made to satisfy the match requirement. The records must indicate the grant and fiscal year for which each matching contribution is counted, how the value placed on third party-in-kind contributions was derived; and to the extent feasible, volunteer services should be supported by the same methods that the organization uses to support the allocation of regular personnel costs. Condition: Source documentation was not maintained to support costs applied to the match. Cause: Personnel changes limited the Organization’s ability to maintain a list of funds expended which were attributed to meeting the match requirements. Potential Effect: Without documentation of funds expended attributed to meeting the match requirement, the Organization could be receiving reimbursements that were for improper amounts. Questioned Costs: The Organization’s 25% match was calculated at $135,900. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should maintain an accounting for all funds expended attributed to meeting the match requirement, as well as the source documentation. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will implement procedures to ensure accounting for funds expended, as well as source documentation, is maintained for costs attributed to meeting the match requirement.

2023-006. Allowable Costs/Cost Principles United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: 24 CFR 578.99(e) of the Uniform Guidance states the requirements of administrative requirements, cost principles, and audit requirements for Federal awards under 2 CFR 200. Condition: An allocation for costs within the administrative components of the budget was not maintained. A percentage of the total administrative budget was requested for reimbursement based on an estimate of costs expended. Cause: Personnel changes limited the Organization’s ability to properly contemporaneously track the allocation of the administrative expense. Potential Effect: Not having a documented allocation of the administrative component of the budget could result in the Organization reporting and receiving reimbursement for the incorrect amount of related costs. Questioned Costs: The administrative budget is $71,544 Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures to ensure that administrative related charges to the program are documented by an allocation calculation. Views of Responsible Officials of Auditee: The Organization agrees with the finding and will implement procedures to ensure an allocation for administrative related expenses is performed and documented.