Audit 388267

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL178L5T172302 - 2024 IL0315L5T142316 - 2024 IL1651L5Y142305 - 2024 IL1780LST172201 - 2023 IL1651L5Tl42204 - 2023 IL0315LST142215 – 2023 Award Periods: August 1, 2023 – July 31, 2024; August 1, 2024 – July 31, 2025; July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Under the Uniform Guidance, organizations are required to document the basis for their procurement. For the procurements tested, the Agency did not have documentation to support how these procurements met the requirements. Condition: While the Agency has a procurement policy in place that meets the requirements of Uniform Guidance, the Agency did not create and retain appropriate documentation for the method of procurement utilized. Questioned Costs: None Context: For one transaction selected for testing under assistance listing number (ALN) 14.267 the Agency utilized the sole source method of procurement but did not maintain documentation justifying why the use of this method was appropriate. Cause: Unknown Effect: Lack of following procurement procedures could result in the Agency engaging vendors who are not the most efficient or economical. Repeat Finding: This finding is a repeat of finding 2024-001. Recommendation: CLA recommends the Agency maintain an audit trail for all procurements. This can be done electronically for efficiency. Views of Responsible Officials: There is no disagreement with this audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL178L5T172302 - 2024 IL0315L5T142316 - 2024 IL1651L5Y142305 - 2024 IL1780LST172201 - 2023 IL1651L5Tl42204 - 2023 IL0315LST142215 – 2023 Award Periods: August 1, 2023 – July 31, 2024; August 1, 2024 – July 31, 2025; July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Agency did not perform the verification of a recurring vendor not suspended or debarred until subsequent to year end. Questioned Costs: None Context: The Agency procured grant writing services and made rental assistance payments to the vendor without performing the verification for the vendor not being suspended or debarred until after the fiscal year end. Cause: Unknown Effect: Formalized procedures should be in place to ensure the Agency does not engage with vendors that are debarred, suspended, or otherwise excluded. Repeat Finding: This finding is a repeat of finding 2024-002. Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Views of Responsible Officials: There is no disagreement with this audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL178L5T172302 - 2024 IL0315L5T142316 - 2024 IL1651L5Y142305 - 2024 IL1780LST172201 - 2023 IL1651L5Tl42204 - 2023 IL0315LST142215 – 2023 Award Periods: August 1, 2023 – July 31, 2024; August 1, 2024 – July 31, 2025; July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Under the Uniform Guidance, compensation for personal services under federal awards must be supported by records that include internal controls ensuring charges that are accurate, allowable, and properly allocated. Condition: The agency did not perform the prescribed policy of having a supervisor signoff on the time of a subordinate within the timecard system. Questioned Costs: None Context: For one of the pay periods tested, the supervisor approval of the employee's timecard for the pay period was not performed and documented by the Agency. Cause: Unknown Effect: Lack of following payroll procedures could lead to inaccurate time and effort being charged to the grant. Repeat Finding: This finding is not a repeat finding. Recommendation: CLA recommends the Agency follow its prescribed policy of supervisors performing and documenting their approval of the documentation of employees' time and effort. Views of Responsible Officials:

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL178L5T172302 - 2024 IL0315L5T142316 - 2024 IL1651L5Y142305 - 2024 IL1780LST172201 - 2023 IL1651L5Tl42204 - 2023 IL0315LST142215 – 2023 Award Periods: August 1, 2023 – July 31, 2024; August 1, 2024 – July 31, 2025; July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Per Uniform Guidance (2 CFR 200.403) costs charged to federal awards must be 1) adequately documented with supporting invoices and receipts and reviewed and approved by authorized personnel prior to payment. Condition: The Agency did not retain documentation supporting the disbursements as well as the control over those disbursements. Questioned Costs: None Context: The Agency did not retain documentation supporting the disbursements as well as the control over those disbursements and the propriety of the expenses charged to the grant cannot be verified due to the change in invoice management systems during the fiscal year for six items tested. Cause: Unknown Effect: Inability to maintain proper supporting documentation over expenses incurred could lead to unallowable costs being reimbursed under the grant. Repeat Finding: This finding is not a repeat finding. Recommendation: CLA recommends the Agency follow established policies to maintain supporting documentation for expenses incurred including their review and approval. Views of Responsible Officials: There is no disagreement with this audit finding.