Adjoin
Schedule of Findings and Questioned Costs
Year Ended December 31, 2024
Section II - Financial Statement Findings Section
None noted.
Section III - Federal Award Findings and Questioned Costs Section
1. Finding Number: Finding 2024-001
Program Name: Supportive Services for Veterans Families: CFDA 64.033
Pass Through Agency: N/A
Type of Finding: Other matters, compliance
a. Criteria: Failure to comply with the grant agreement’s terms and applicable
regulations: The Organization did not comply with grant compliance requirements
such as tracking administrative expenses charged to the program outside of the
general ledger and in other matters noted in Supportive Services for Veterans
Families (SSVF) reviews.
b. Condition: During our audit, JGD reviewed the results of all reviews for the SSVF
grant and noted seven compliance deficiencies were indicated in the reporting period.
These deficiencies resulted in a failure of controls over compliance.
Under the SSVF Program, a minimum of 90% of supportive services grant funds must
be used to provide and coordinate the provision of supportive services to very lowincome
Veteran families who are occupying permanent housing. A maximum of 10%
of supportive services grant funds may be used for administrative costs. Per Section
62.70 of the 38 CFR Part 62, administrative costs are defined as all direct and indirect
costs associated with the indirect, of subcontractors. SSVF requires grantees to
provide support documentation (payroll records, invoices, receipts etc.) for all costs
and expenses associated with the administration of the SSVF grant.
Administrative costs should be placed in the Administrative section of an SSVF
program budget. An approved Indirect Cost Rate is not considered adequate support
or source documentation for costs listed in the Administrative section of the budget.
Grantees are required to have a detailed breakout of these administrative costs along
with any supporting documents for those expenses for auditing and oversight. Title 2
CFR 200.302 requires the financial management system of each non-Federal entity
provide “records that identify adequately the source and application of funds for
federally-funded activities. These records must contain information pertaining to
Federal awards, authorizations, obligations, unobligated balances, assets,
expenditures, income and interest and be supported by source documentation.”
These citations are included for informational purposes:
Fiscal Administration – Administrative Expenses: Administrative expenses
were not recorded in the general ledger, resulting in questioned costs.
Fiscal Administration – Unallowed Supplemental Pay: Five employees did not
have evidence to support reasonableness and compliance with incentive
compensation requirements, resulting in questioned costs.
25
Adjoin
Schedule of Findings and Questioned Costs
Year Ended December 31, 2024
Fiscal Administration – Inadequate TFA Identification: TFA expenses were not
paid through credit card charges in the general ledger. This deficiency was
cleared as corrective action was taken during the review.
Participant Eligibility – HMIS Release of Information Forms: Four case files
were missing HMIS Release of Information Forms for household members
over the age of 18.
Participant Eligibility – Missing Income Eligibility Documentation: Three case
files missing income eligibility documents for Veterans and one case file
missing income eligibility documents for Veteran and household members at
certification of eligibility events.
Participant Eligibility – Missing Exit Checklist: Five case files did not include
exit checklist documentation. This deficiency was cleared as corrective action
was taken during the review.
Program Operations – Inadequate MOU: MOU for a legal subcontractor was
missing required elements, including expectations and requirements for
quarterly assessments and annual monitoring of performance, listing of only
eligible/allowable legal services, highlighting of response time expectations
and requirements to support payments, and account for Veterans that have
been separated from the program and those in need of long-term legal
services.
c. Context: Recipients of Federal grants are required to comply with all terms and
applicable regulations of grant agreements.
d. Questioned Costs: Administrative expenses resulted in $937,794 and supplemental
pay resulted in $1,500 in questioned costs. The Organization has disputed both
findings noting the expenses are itemized within their internal tracking files and that
the costs are allowable, allocable, and reasonable. The Organization has received no
response from the agency.
e. Cause: Internal accounting procedures, lack of compliance policies, and lack of
training over verification and documentation processes, resulting in a failure of
controls over compliance.
f. Effect: Considered to be an other matter related to internal control over compliance.
g. Recommendation: Management should take steps to ensure that all administrative
expenses are properly recorded in the general ledger, supplemental pay is approved
with proper evidence of approvals, and proper documentation and policies are in
place to comply with all grant compliance requirements.
We recommend that management closely monitor areas of non-compliance as noted
in the licensing reviews.
Section IV – Schedule of Prior Year Findings and Questioned Costs
None noted.
Adjoin
Schedule of Findings and Questioned Costs
Year Ended December 31, 2024
Section II - Financial Statement Findings Section
None noted.
Section III - Federal Award Findings and Questioned Costs Section
1. Finding Number: Finding 2024-001
Program Name: Supportive Services for Veterans Families: CFDA 64.033
Pass Through Agency: N/A
Type of Finding: Other matters, compliance
a. Criteria: Failure to comply with the grant agreement’s terms and applicable
regulations: The Organization did not comply with grant compliance requirements
such as tracking administrative expenses charged to the program outside of the
general ledger and in other matters noted in Supportive Services for Veterans
Families (SSVF) reviews.
b. Condition: During our audit, JGD reviewed the results of all reviews for the SSVF
grant and noted seven compliance deficiencies were indicated in the reporting period.
These deficiencies resulted in a failure of controls over compliance.
Under the SSVF Program, a minimum of 90% of supportive services grant funds must
be used to provide and coordinate the provision of supportive services to very lowincome
Veteran families who are occupying permanent housing. A maximum of 10%
of supportive services grant funds may be used for administrative costs. Per Section
62.70 of the 38 CFR Part 62, administrative costs are defined as all direct and indirect
costs associated with the indirect, of subcontractors. SSVF requires grantees to
provide support documentation (payroll records, invoices, receipts etc.) for all costs
and expenses associated with the administration of the SSVF grant.
Administrative costs should be placed in the Administrative section of an SSVF
program budget. An approved Indirect Cost Rate is not considered adequate support
or source documentation for costs listed in the Administrative section of the budget.
Grantees are required to have a detailed breakout of these administrative costs along
with any supporting documents for those expenses for auditing and oversight. Title 2
CFR 200.302 requires the financial management system of each non-Federal entity
provide “records that identify adequately the source and application of funds for
federally-funded activities. These records must contain information pertaining to
Federal awards, authorizations, obligations, unobligated balances, assets,
expenditures, income and interest and be supported by source documentation.”
These citations are included for informational purposes:
Fiscal Administration – Administrative Expenses: Administrative expenses
were not recorded in the general ledger, resulting in questioned costs.
Fiscal Administration – Unallowed Supplemental Pay: Five employees did not
have evidence to support reasonableness and compliance with incentive
compensation requirements, resulting in questioned costs.
25
Adjoin
Schedule of Findings and Questioned Costs
Year Ended December 31, 2024
Fiscal Administration – Inadequate TFA Identification: TFA expenses were not
paid through credit card charges in the general ledger. This deficiency was
cleared as corrective action was taken during the review.
Participant Eligibility – HMIS Release of Information Forms: Four case files
were missing HMIS Release of Information Forms for household members
over the age of 18.
Participant Eligibility – Missing Income Eligibility Documentation: Three case
files missing income eligibility documents for Veterans and one case file
missing income eligibility documents for Veteran and household members at
certification of eligibility events.
Participant Eligibility – Missing Exit Checklist: Five case files did not include
exit checklist documentation. This deficiency was cleared as corrective action
was taken during the review.
Program Operations – Inadequate MOU: MOU for a legal subcontractor was
missing required elements, including expectations and requirements for
quarterly assessments and annual monitoring of performance, listing of only
eligible/allowable legal services, highlighting of response time expectations
and requirements to support payments, and account for Veterans that have
been separated from the program and those in need of long-term legal
services.
c. Context: Recipients of Federal grants are required to comply with all terms and
applicable regulations of grant agreements.
d. Questioned Costs: Administrative expenses resulted in $937,794 and supplemental
pay resulted in $1,500 in questioned costs. The Organization has disputed both
findings noting the expenses are itemized within their internal tracking files and that
the costs are allowable, allocable, and reasonable. The Organization has received no
response from the agency.
e. Cause: Internal accounting procedures, lack of compliance policies, and lack of
training over verification and documentation processes, resulting in a failure of
controls over compliance.
f. Effect: Considered to be an other matter related to internal control over compliance.
g. Recommendation: Management should take steps to ensure that all administrative
expenses are properly recorded in the general ledger, supplemental pay is approved
with proper evidence of approvals, and proper documentation and policies are in
place to comply with all grant compliance requirements.
We recommend that management closely monitor areas of non-compliance as noted
in the licensing reviews.
Section IV – Schedule of Prior Year Findings and Questioned Costs
None noted.