Audit 372297

2024-009 Matching, Level of Effort, Earmarking Assistance Listing No.: 14.267 Continuum of Care Program (“CoC’) Condition: The Organization was unable to demonstrate controls over the matching and earmarking requirements. Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)). No more than 10 percent of any grant awarded may be used for paying costs of administering the assistance. Administrative costs include the costs associated with general management oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA cost (24 CRR section 578.59). Questioned Costs There are no questioned costs. Cause: The Organization did not have sufficient controls to ensure that the matching and earmarking requirements were met. Effect: It is more likely that the Organization will not meet the percent matching requirements and earmarking since there is no formal set of controls over the requirements. Perspective: This is a systemic issue in that controls over the requirements have not been developed to ensure the reported information is accurate. Repeat Finding: This is a repeat finding. See finding 2023-013. Recommendation: In order to prevent future occurrences of this deficiency, RBT recommends that management develop a set of controls to ensure that they are meeting 25% match and 10% earmarking requirements. Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.

2024-010 Period of Performance Assistance Listing No.: 14.267 Continuum of Care Program Condition: The Organization was unable to demonstrate consistent controls over the period of performance requirement. Criteria: The requirements for the period of performance are contained in 2 CFR section 200.1 Definitions for “budget period,” “financial obligations,” “period of performance,” 2 CFR section 200.308 (revision of budget and program plans), 2 CFR section 200.309 (modifications to period of performance), 2 CFR section 200.344 (closeout), program legislation, federal awarding agency regulations; and the terms and conditions of the award. Questioned Costs There are no questioned costs. Cause: The Organization did not have good controls on ensuring the period of performance requirement was met due to staff turn over. Effect: The Organization could have incurred grant expenditures outside the grant period. Perspective: Two of forty items selected for testing did not have documentation of the control over compliance with the period of performance requirement. Repeat Finding: This is a repeat finding. See finding 2023-014. Based on timing of prior year audit the Organization did not have time to fully correct the issue. Recommendation: In order to prevent future occurences of this deficiency, RBT recommends that management expand controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.

2024-011 Procurement and Suspension and Debarment Assistance Listing No.: 14.267 Continuum of Care Program Condition: The Organization was unable to demonstrate consistent controls over the procurement requirement. Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract. Questioned Costs There is no questioned cost. Cause: The Organization did not have sufficient controls to ensure that the procurement requirement was met due to staff turnover. Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy. Perspective: Two of the forty items selected for testing did not have documentation of the control over compliance with the procurement and suspension and debarment requirement. Repeat Finding: This is a repeat finding. See finding 2023-015. Based on timing of prior year audit the Organization did not have time to fully correct the issue. Recommendation: In order to prevent future occurences of this deficiency, RBT recommends that management expand controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Auditee Response: The Organization agrees with the finding. See attached corrective action plan.

2024-012 Allowable and Unallowable Costs Assistance Listing No.: 16.575 Crime Victims Assistance and 94.006 AmeriCorps Program Condition: The Organization did not have controls over allowable and unallowable costs requirements. Criteria: The expenditures were necessary and reasonable for performance of the federal award and allowable costs under grants and cooperative agreements are contained in 2 CFR sections 200 subpart E. Questioned Costs There are no questioned costs. Cause: The Organization did not have sufficient controls to ensure that the allowable and unallowable costs requirement was met due to staff turnover. Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy and were unallowable under the grant. Perspective: Thirteen of the sixty-five items selected for testing did not have documentation of the control over compliance with the allowable and unallowable cost requirement. Repeat Finding: This is a repeat finding. See finding 2023-016. Based on timing of prior year audit the Organization did not have time to fully correct the issue. Recommendation: In order to prevent future occurrences of this deficiency, RBT recommends that management expand controls to ensure that they are able to demonstrate that all expenses meet their procurement policy and are allowable under the grant. Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.