Audit 369634

Significant Deficiencies 2024-001. 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: 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. Effect: Not having the updated policies and procedures could weaken the internal controls over expenditures charged to the federal award. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2023-001. Questioned Costs: Dollar amount undetermined. Recommendation: The Organization should update it’s 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.

2024-002. 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 compensation-personal 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. Time records prepared by employees do not reflect the actual time spent on programs funded by a federal award, rather they are based on budgeted hours. Cause: The Organization allocates payroll to programs funded by awards based on the contract supported budget, which is based on an estimate of the time that work will be performed by individuals. At the time of the audit, the true-up of budgeted hours to actual hours worked had not been completed. Effect: Reimbursement for compensation under federal awards without time records that differentiate between activities conducted, such as personnel activity equivalent reports, might result in the incorrect payment amount of payroll expenses. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2023-002. Questioned Costs: Dollar amount undetermined. 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 that 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.

2024-003. Special Tests and Provisions United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Criteria: Grants used to pay rent for individual housing units, should document rent paid is reasonable in relation to rents being charged for comparable units, taking into account relevant features. In addition, 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 HUD-determined 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 because of staffing constraints, a review of a selection of tenant files was performed for compliance with this criteria.Effect: The Organization may be paying rent that is not reasonable in relation to comparable rent in the area. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2023-004. Questioned Costs: Dollar amount undetermined. 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.