Finding 2024-003: Noncompliance with Period of Performance Requirement
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (PRC RR, Northern PSH Combo, and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2023 to March 31, 2024 Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024 PRC RR (Grant no. NC 0125) June 1, 2023 to May 31, 2024
Type of Finding: Significant Deficiency and Noncompliance
Condition and Criteria: Rent reasonableness should be assessed on an annual basis.
Cause: Community Link has a policy to perform a rent reasonableness assessment when the client enters the program, but there is no policy to update that assessment on an annual basis.
Effect: Community Link is not comparing the current rent to the market rent rates.
Recommendation: We recommend that management implements a policy to review rent reasonableness on an annual basis at a minimum. We also recommend performing a rent reasonableness assessment if rental rates charged for the same unit are increased.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. Community Link will update the policy and procedure manual to add that rent reasonable will be completed annually for customers in CoC programs and when rental increases are assessed by the Property provider. Currently, staff are in communication with property providers when an increase is assessed, so the increased rents stay within the FMR for the area.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Finding 2024-001: Noncompliance with Matching Requirement
Recommendation: It is our understanding that the organization has already been in discussions with HUD regarding its inability to secure sufficient matching funds and is seeking to discontinue its administration of this program. As of July 2024, the NC0045 has been transferred to another organization.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. The Organization will continue working with HUD to transfer these award programs to another entity that has more capacity of complying with all requirements. As of July 2024, grant NC0045 was transferred to Brick Capital. The Organization is continuing to work with HUD to transfer the NC0221 grant.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (Northern PSH Combo and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2024 to March 31, 2024
Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024
Type of Finding: Noncompliance
Condition and Criteria: Matching requirement is 25% of all grant funds except for leasing funds. However, for Grant no. NC 0045 we noted that the Organization provided matching funds at approximately 8% and for Grant no. NC 0221 we noted that the Organization provided matching funds at approximately 4%. Total expenditures of federal awards was approximately $1.1 million for NC 0221 and $1.2M for NC 0045 these grants.
Cause: The Organization and HUD were both aware of the Organization’s past difficulties in securing sufficient matching funds for both of these grant programs. Accordingly, in a prior year HUD waived the matching requirement in order to provide the Organization with more time to attempt to secure sufficient matching funds. However, the Organization was not successful in that effort and HUD declined to provide a waiver that would extend past June 30, 2022.
Effect: The Organization has not provided sufficient matching funds and as a result is not in compliance with the 25% matching requirement. This condition could result in the Organization losing funding due to noncompliance. However, as further discussed below the Organization is already in discussions with HUD regarding its potential discontinuance with these specific programs. Grant 0045 was transferred to another agency subsequent to year end.
Finding 2024-002: Noncompliance with Period of Performance Requirement
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. Management will make sure all electronic invoices for customer payments are created and approved within the grant term. For payments that occur during the last month of the grant term, the staff will make sure all invoices are submitted to management within the first two weeks of the month, which will give time if an invoice needs to be corrected and sent back for updating. If there is a holiday within that month, management will make sure to communicate a deadline to staff for getting invoices in so they can be approved within that month and not carried over into the next month if the holiday falls at the end of the month.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2023 to March 31, 2024
Type of Finding: Significant Deficiency and Noncompliance
Condition and Criteria: There was one cost that was charged to the grant that were incurred prior to the period of performance start date for the NC0045 grant.
Cause: The cost was charged to the grant in April due to the final approval not being submitted until April, however, the cost was incurred in the prior month and approved from the by the first approver in the prior month.
Effect: The organization charged costs to the grant that were not incurred during the grant period.
Recommendation: We recommend that the Organization charge grant expenses based on when the expense was incurred, not when the payment was due or the grant expense was approved.
Finding 2024-003: Noncompliance with Period of Performance Requirement
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (PRC RR, Northern PSH Combo, and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2023 to March 31, 2024 Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024 PRC RR (Grant no. NC 0125) June 1, 2023 to May 31, 2024
Type of Finding: Significant Deficiency and Noncompliance
Condition and Criteria: Rent reasonableness should be assessed on an annual basis.
Cause: Community Link has a policy to perform a rent reasonableness assessment when the client enters the program, but there is no policy to update that assessment on an annual basis.
Effect: Community Link is not comparing the current rent to the market rent rates.
Recommendation: We recommend that management implements a policy to review rent reasonableness on an annual basis at a minimum. We also recommend performing a rent reasonableness assessment if rental rates charged for the same unit are increased.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. Community Link will update the policy and procedure manual to add that rent reasonable will be completed annually for customers in CoC programs and when rental increases are assessed by the Property provider. Currently, staff are in communication with property providers when an increase is assessed, so the increased rents stay within the FMR for the area.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Finding 2024-001: Noncompliance with Matching Requirement
Recommendation: It is our understanding that the organization has already been in discussions with HUD regarding its inability to secure sufficient matching funds and is seeking to discontinue its administration of this program. As of July 2024, the NC0045 has been transferred to another organization.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. The Organization will continue working with HUD to transfer these award programs to another entity that has more capacity of complying with all requirements. As of July 2024, grant NC0045 was transferred to Brick Capital. The Organization is continuing to work with HUD to transfer the NC0221 grant.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (Northern PSH Combo and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2024 to March 31, 2024
Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024
Type of Finding: Noncompliance
Condition and Criteria: Matching requirement is 25% of all grant funds except for leasing funds. However, for Grant no. NC 0045 we noted that the Organization provided matching funds at approximately 8% and for Grant no. NC 0221 we noted that the Organization provided matching funds at approximately 4%. Total expenditures of federal awards was approximately $1.1 million for NC 0221 and $1.2M for NC 0045 these grants.
Cause: The Organization and HUD were both aware of the Organization’s past difficulties in securing sufficient matching funds for both of these grant programs. Accordingly, in a prior year HUD waived the matching requirement in order to provide the Organization with more time to attempt to secure sufficient matching funds. However, the Organization was not successful in that effort and HUD declined to provide a waiver that would extend past June 30, 2022.
Effect: The Organization has not provided sufficient matching funds and as a result is not in compliance with the 25% matching requirement. This condition could result in the Organization losing funding due to noncompliance. However, as further discussed below the Organization is already in discussions with HUD regarding its potential discontinuance with these specific programs. Grant 0045 was transferred to another agency subsequent to year end.
Finding 2024-003: Noncompliance with Period of Performance Requirement
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (PRC RR, Northern PSH Combo, and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2023 to March 31, 2024 Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024 PRC RR (Grant no. NC 0125) June 1, 2023 to May 31, 2024
Type of Finding: Significant Deficiency and Noncompliance
Condition and Criteria: Rent reasonableness should be assessed on an annual basis.
Cause: Community Link has a policy to perform a rent reasonableness assessment when the client enters the program, but there is no policy to update that assessment on an annual basis.
Effect: Community Link is not comparing the current rent to the market rent rates.
Recommendation: We recommend that management implements a policy to review rent reasonableness on an annual basis at a minimum. We also recommend performing a rent reasonableness assessment if rental rates charged for the same unit are increased.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. Community Link will update the policy and procedure manual to add that rent reasonable will be completed annually for customers in CoC programs and when rental increases are assessed by the Property provider. Currently, staff are in communication with property providers when an increase is assessed, so the increased rents stay within the FMR for the area.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Finding 2024-003: Noncompliance with Period of Performance Requirement
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (PRC RR, Northern PSH Combo, and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2023 to March 31, 2024 Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024 PRC RR (Grant no. NC 0125) June 1, 2023 to May 31, 2024
Type of Finding: Significant Deficiency and Noncompliance
Condition and Criteria: Rent reasonableness should be assessed on an annual basis.
Cause: Community Link has a policy to perform a rent reasonableness assessment when the client enters the program, but there is no policy to update that assessment on an annual basis.
Effect: Community Link is not comparing the current rent to the market rent rates.
Recommendation: We recommend that management implements a policy to review rent reasonableness on an annual basis at a minimum. We also recommend performing a rent reasonableness assessment if rental rates charged for the same unit are increased.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. Community Link will update the policy and procedure manual to add that rent reasonable will be completed annually for customers in CoC programs and when rental increases are assessed by the Property provider. Currently, staff are in communication with property providers when an increase is assessed, so the increased rents stay within the FMR for the area.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Finding 2024-001: Noncompliance with Matching Requirement
Recommendation: It is our understanding that the organization has already been in discussions with HUD regarding its inability to secure sufficient matching funds and is seeking to discontinue its administration of this program. As of July 2024, the NC0045 has been transferred to another organization.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. The Organization will continue working with HUD to transfer these award programs to another entity that has more capacity of complying with all requirements. As of July 2024, grant NC0045 was transferred to Brick Capital. The Organization is continuing to work with HUD to transfer the NC0221 grant.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (Northern PSH Combo and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2024 to March 31, 2024
Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024
Type of Finding: Noncompliance
Condition and Criteria: Matching requirement is 25% of all grant funds except for leasing funds. However, for Grant no. NC 0045 we noted that the Organization provided matching funds at approximately 8% and for Grant no. NC 0221 we noted that the Organization provided matching funds at approximately 4%. Total expenditures of federal awards was approximately $1.1 million for NC 0221 and $1.2M for NC 0045 these grants.
Cause: The Organization and HUD were both aware of the Organization’s past difficulties in securing sufficient matching funds for both of these grant programs. Accordingly, in a prior year HUD waived the matching requirement in order to provide the Organization with more time to attempt to secure sufficient matching funds. However, the Organization was not successful in that effort and HUD declined to provide a waiver that would extend past June 30, 2022.
Effect: The Organization has not provided sufficient matching funds and as a result is not in compliance with the 25% matching requirement. This condition could result in the Organization losing funding due to noncompliance. However, as further discussed below the Organization is already in discussions with HUD regarding its potential discontinuance with these specific programs. Grant 0045 was transferred to another agency subsequent to year end.
Finding 2024-002: Noncompliance with Period of Performance Requirement
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. Management will make sure all electronic invoices for customer payments are created and approved within the grant term. For payments that occur during the last month of the grant term, the staff will make sure all invoices are submitted to management within the first two weeks of the month, which will give time if an invoice needs to be corrected and sent back for updating. If there is a holiday within that month, management will make sure to communicate a deadline to staff for getting invoices in so they can be approved within that month and not carried over into the next month if the holiday falls at the end of the month.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2023 to March 31, 2024
Type of Finding: Significant Deficiency and Noncompliance
Condition and Criteria: There was one cost that was charged to the grant that were incurred prior to the period of performance start date for the NC0045 grant.
Cause: The cost was charged to the grant in April due to the final approval not being submitted until April, however, the cost was incurred in the prior month and approved from the by the first approver in the prior month.
Effect: The organization charged costs to the grant that were not incurred during the grant period.
Recommendation: We recommend that the Organization charge grant expenses based on when the expense was incurred, not when the payment was due or the grant expense was approved.
Finding 2024-003: Noncompliance with Period of Performance Requirement
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (PRC RR, Northern PSH Combo, and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2023 to March 31, 2024 Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024 PRC RR (Grant no. NC 0125) June 1, 2023 to May 31, 2024
Type of Finding: Significant Deficiency and Noncompliance
Condition and Criteria: Rent reasonableness should be assessed on an annual basis.
Cause: Community Link has a policy to perform a rent reasonableness assessment when the client enters the program, but there is no policy to update that assessment on an annual basis.
Effect: Community Link is not comparing the current rent to the market rent rates.
Recommendation: We recommend that management implements a policy to review rent reasonableness on an annual basis at a minimum. We also recommend performing a rent reasonableness assessment if rental rates charged for the same unit are increased.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. Community Link will update the policy and procedure manual to add that rent reasonable will be completed annually for customers in CoC programs and when rental increases are assessed by the Property provider. Currently, staff are in communication with property providers when an increase is assessed, so the increased rents stay within the FMR for the area.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Finding 2024-001: Noncompliance with Matching Requirement
Recommendation: It is our understanding that the organization has already been in discussions with HUD regarding its inability to secure sufficient matching funds and is seeking to discontinue its administration of this program. As of July 2024, the NC0045 has been transferred to another organization.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. The Organization will continue working with HUD to transfer these award programs to another entity that has more capacity of complying with all requirements. As of July 2024, grant NC0045 was transferred to Brick Capital. The Organization is continuing to work with HUD to transfer the NC0221 grant.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (Northern PSH Combo and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2024 to March 31, 2024
Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024
Type of Finding: Noncompliance
Condition and Criteria: Matching requirement is 25% of all grant funds except for leasing funds. However, for Grant no. NC 0045 we noted that the Organization provided matching funds at approximately 8% and for Grant no. NC 0221 we noted that the Organization provided matching funds at approximately 4%. Total expenditures of federal awards was approximately $1.1 million for NC 0221 and $1.2M for NC 0045 these grants.
Cause: The Organization and HUD were both aware of the Organization’s past difficulties in securing sufficient matching funds for both of these grant programs. Accordingly, in a prior year HUD waived the matching requirement in order to provide the Organization with more time to attempt to secure sufficient matching funds. However, the Organization was not successful in that effort and HUD declined to provide a waiver that would extend past June 30, 2022.
Effect: The Organization has not provided sufficient matching funds and as a result is not in compliance with the 25% matching requirement. This condition could result in the Organization losing funding due to noncompliance. However, as further discussed below the Organization is already in discussions with HUD regarding its potential discontinuance with these specific programs. Grant 0045 was transferred to another agency subsequent to year end.
Finding 2024-003: Noncompliance with Period of Performance Requirement
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program (PRC RR, Northern PSH Combo, and Piedmont)
Assistance Listing Number: 14.267
Award Period: Northern PSH Combo (Grant no. NC 0045) April 1, 2023 to March 31, 2024 Piedmont (Grant no. NC 0221) June 1, 2023 to May 31, 2024 PRC RR (Grant no. NC 0125) June 1, 2023 to May 31, 2024
Type of Finding: Significant Deficiency and Noncompliance
Condition and Criteria: Rent reasonableness should be assessed on an annual basis.
Cause: Community Link has a policy to perform a rent reasonableness assessment when the client enters the program, but there is no policy to update that assessment on an annual basis.
Effect: Community Link is not comparing the current rent to the market rent rates.
Recommendation: We recommend that management implements a policy to review rent reasonableness on an annual basis at a minimum. We also recommend performing a rent reasonableness assessment if rental rates charged for the same unit are increased.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. Community Link will update the policy and procedure manual to add that rent reasonable will be completed annually for customers in CoC programs and when rental increases are assessed by the Property provider. Currently, staff are in communication with property providers when an increase is assessed, so the increased rents stay within the FMR for the area.
Name of the Contact Person Responsible for the Corrective Action: Tameka Gunn, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: March 2025