Cost Sharing and Level of Effort Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Homeless Challenge Grant Assistance Listing Number: 93.558 Federal Award Identification Number and Year: IP004 - 2025 Pass-Through Agency: Palm Beach County Board of County Commissioners Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria: Cash amounts reported as cost sharing may not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program. In addition, recipients are required to document and meet all level‑of‑effort requirements and maintain documentation demonstrating compliance with program service requirements as specified in the grant agreement. Condition: During testing, the Organization did not maintain adequate internal controls to ensure compliance with cost‑sharing and level‑of‑effort requirements under the Homeless Challenge Grant. Specifically, costs reported as cash matching funds included amounts paid with other federal funds, required level‑of‑effort documentation was incomplete or not reviewed, and the Organization did not meet all required service and effort benchmarks during the grant period. Questioned costs: $24,473 of the $43,664 expenses reported to the grantor were unallowable as determined by the financial reports received. Context: Audit testing identified multiple compliance failures related to cost sharing and level‑of‑effort requirements. Of the expenses reported as cash matching funds, $24,473 were paid using other federal funds. Additionally, documentation supporting required level‑of‑effort measures was incomplete, and 3 of 6 required effort benchmarks were not met during the grant period. Cause: The Organization lacked sufficient review controls and monitoring procedures to ensure that cost‑sharing expenditures were allowable, level‑of‑effort documentation was complete, and required program benchmarks were achieved. Effect: Failure to comply with cost‑sharing and level‑of‑effort requirements could, at the grantor’s discretion, jeopardize current or future funding and result in disallowed costs. Repeat finding: No Recommendation: Management should strengthen internal review controls to ensure that cost‑sharing expenditures are allowable, level‑of‑effort requirements are fully documented and reviewed, and program benchmarks are monitored throughout the grant period to ensure compliance with grant requirements. Views of responsible officials: There is no disagreement with the audit finding.
Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Homeless Challenge Grant Assistance Listing Number: 93.558 Federal Award Identification Number and Year: IP004 - 2025 Pass-Through Agency: Palm Beach County Board of County Commissioners Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria: Eligibility determinations must be reviewed by an individual other than the preparer to ensure that only eligible participants are served in accordance with the grant agreement. Condition: During our testing, we noted that the Organization did not have adequate internal controls to ensure eligibility intake forms were reviewed by an individual other than the preparer. Questioned costs: None. Context: Of the eight eligibility intake forms selected for testing, four were not reviewed by an individual other than the preparer. The review of intake forms is the sole key control over participant eligibility for this program. Cause: The Organization lacked a review process requiring eligibility determinations to be reviewed by someone independent of the preparer. Effect: Without an independent review of eligibility determinations, the Organization could allow ineligible participants into the program, resulting in noncompliance with grant requirements and potential disallowed costs. Repeat finding: No Recommendation: Eligibility intake forms should be reviewed by an individual other than the preparer to ensure that only eligible participants are served under the Homeless Challenge Grant. Views of responsible officials: There is no disagreement with the audit finding.
Allowable Costs Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Homeless Challenge Grant Assistance Listing Number: 93.558 Federal Award Identification Number and Year: IP004 - 2025 Pass-Through Agency: Palm Beach County Board of County Commissioners Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria: Payroll and other costs charged to a federal award must be supported by adequate documentation demonstrating that the costs were incurred, are allowable, and are allocable to the program in accordance with the terms of the grant agreement and federal cost principles. Condition: During our testing, we noted the Organization did not have adequate documentation to support the total amount of payroll expenses requested for reimbursement under the Homeless Challenge Grant. Questioned costs: $30,730 of the $60,782 payroll expenses requested for reimbursement could not be substantiated with supporting documentation. Context: The grant allows payroll expenses to be allocated evenly throughout the grant period. However, the Organization was unable to provide supporting documentation for $30,730 of the $60,782 requested for reimbursement for payroll costs during the audit period. Cause: The Organization lacked adequate documentation and review controls to ensure payroll expenses charged to the grant were fully supported and properly substantiated. Effect: Without adequate documentation, payroll costs may be requested for reimbursement that were not actually incurred or are otherwise unallowable, which could result in disallowed costs and jeopardize current or future funding. Repeat finding: No Recommendation: Management should ensure that all payroll costs charged to the program are supported by adequate documentation demonstrating that the costs were incurred and allocable to the Homeless Challenge Grant. Views of responsible officials: There is no disagreement with the audit finding.
Eligibility and Procurement Federal Agency: U.S. Department of Justice Federal Program Name: Services for Trafficking Victims Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 15POVC‑23‑GK‑02725‑HT; 15POVC‑24‑GG‑01548‑HT Pass-Through Agency: Palm Beach County Board of County Commissioners Award Period: October 1, 2023 – September 30, 2026; October 1, 2024 – September 30, 2027 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria: Eligibility determinations must be reviewed by an individual other than the preparer to ensure only eligible participants are served. In addition, recipients are required to maintain written procurement policies and procedures that comply with Uniform Guidance requirements, including procedures for procurements exceeding the micro‑purchase threshold. Condition: During our testing, we noted the Organization did not have adequate internal controls to ensure compliance with eligibility and procurement requirements. Specifically, eligibility assessments were not reviewed by an individual other than the preparer, and the Organization’s procurement policy did not address procurement requirements for vendors other than construction, as required by Uniform Guidance. Questioned costs: None Context: All nine eligibility assessments selected for testing were not reviewed by an individual other than the preparer. The review of eligibility assessments is the sole key control over participant eligibility for this program and is therefore pervasive. Additionally, while the Organization maintains a procurement policy for construction vendors, the policy does not address procurement requirements applicable to other vendor types, increasing the risk of noncompliant purchasing practices. Cause: The Organization lacked sufficient review procedures over eligibility determinations and did not maintain comprehensive procurement policies that address all Uniform Guidance procurement requirements. Effect: Without independent review of eligibility determinations, the Organization could allow ineligible participants into the program. Inadequate procurement policies increase the risk that purchases are made inconsistently or in noncompliance with federal requirements, potentially resulting in disallowed costs or questioned expenditures. Repeat finding: No Recommendation: Management should implement a review process requiring eligibility assessments to be reviewed by an individual other than the preparer and update procurement policies to fully comply with Uniform Guidance requirements, including procedures for procurements exceeding the micro‑purchase threshold. Views of responsible officials: There is no disagreement with the audit finding.
Period of Performance Federal Agency: U.S. Department of Justice Federal Program Name: Services for Trafficking Victims Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 15POVC‑24‑GG‑01548‑HT Pass-Through Agency: Palm Beach County Board of County Commissioners Award Period: October 1, 2024 – September 30, 2027 Type of Finding: • Significant deficiency in Internal Control over Compliance Criteria: Expenses requested for reimbursement must be incurred during the approved grant period in accordance with the terms and conditions of the federal award. Condition: During our testing, we noted the Organization requested reimbursement for costs that were incurred outside the approved grant period. Questioned costs: $168.34 was calculated as unallowable after calculating the portion of the invoice attributable to dates outside the award period. Context: Of the 5 expenses selected for testing related to reimbursement requests during the first month of the grant period, 3 were partially incurred prior to the beginning of the grant period. Cause: The Organization lacked sufficient review procedures to ensure that expenses submitted for reimbursement were incurred within the approved grant period. Effect: Without adequate controls over period‑of‑performance requirements, the Organization could request reimbursement for unallowable costs, resulting in disallowed expenditures and potential repayment to the grantor. Repeat finding: No Recommendation: Management should implement review procedures to ensure that all expenses submitted for reimbursement are incurred within the approved grant period prior to submission. Views of responsible officials: There is no disagreement with the audit finding.