Audit 403529

FINDING 2025‐001—ALLOWABLE COSTS/COST PRINCIPLES AND ACTIVITIES ALLOWED AND UNALLOWED AND SPECIAL TEST – DRAWDOWNS OF HOME/HOME ARP FUNDS—MATERIAL WEAKNESS IN INTERNAL CONTROLS OVER COMPLIANCE FEDERAL PROGRAM: Home Investment Partnerships Program (HOME) ASSISTANCE LISTING NUMBER: 14.239 YEAR(S): 2025 FEDERAL AGENCY: Department Of Housing and Urban Development (HUD) PASS‐THROUGH AGENCIES: Idaho Housing and Finance Association Criteria - In accordance with 2 CFR 200.303 the recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context - On a periodic basis management submits draw-down requests to the pass-through agency. Management could not provide documentation to evidence that a review was performed over 100% of the draw-down requests prior to their submission. Further, during the testing of the underlying expenses, which are the primary inputs into the above-mentioned drawdown requests, management was able to evidence their review of payroll expenses via approved time sheets. However, non-payroll expenses and their associated indirect cost allocation calculations did not have evidence of management’s review for allowability. Cause - Management did not design and implement a control that required documented evidence of review and approval of the drawdown request. The control also did not ensure that the evidence of review of the underlying non-payroll expenses and indirect cost allocation calculations were retained. Effect - Management may not be able to detect and prevent unallowable expenses from being submitted to the passthrough agency for reimbursement, which could result in unallowed expenses being charged to the grant. Questioned Cost - Not Applicable Recommendation - Management should design and implement a control that ensures sufficient evidence of approval is obtained and retained, including underlying indirect cost allocation calculations and non-payroll costs. View of Responsible Officials - See Corrective Action Plan.

FINDING 2025‐002—ELIGIBILITY—SIGNIFICANT DEFICIENCY IN INTERNAL CONTROLS OVER COMPLIANCE AND NONCOMPLIANCE FEDERAL PROGRAM: Home Investment Partnerships Program (HOME) ASSISTANCE LISTING NUMBER: 14.239 YEAR(S): 2025 FEDERAL AGENCY: Department Of Housing and Urban Development (HUD) PASS‐THROUGH AGENCIES: Idaho Housing and Finance Association Criteria - Only low income or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR section 92.1). Therefore, the entity must determine if each family is income eligible by determining the family’s annual income, including all persons in the household, as provided for in 24 CFR section 92.203. The entity must maintain records for each family assisted (24 CFR section 92.508). Condition/Context – From 32 selections of a management prepared listing of participants who received housing or utility assistance, management could not provide documentation verifying eligibility, nor the dollar value provided to, 2 of the samples. Further, 4 out of the 32 selections had an initial intake case manager signature on the application, however there was no evidence that a secondary review of eligibility was performed. Cause - Management has not designed and implemented a control to ensure all eligibility documentation is maintained for program participants; further, management did not perform or retain evidence of a secondary review of participant eligibility. Effect - Assistance could be provided to participants who were ineligible, reducing the amount of funding available for eligible participants. Questioned Cost - Could not be determined. Management was unable to verify whether the 2 selections that had missing documentation received any assistance from the federal awards. Recommendation - Management should design a control to ensure all the documentation is maintained for the applicants regarding their application status and further ensure documentation is maintained evidencing that a secondary review was performed over all applications. View of Responsible Officials - See Corrective Action Plan.

FINDING 2025‐003— ALLOWABLE COSTS/COST PRINCIPLES AND ACTIVITIES ALLOWED AND UNALLOWED—SIGNIFICANT DEFICIENCY IN INTERNAL CONTROLS OVER COMPLIANCE AND NONCOMPLIANCE FEDERAL PROGRAM: Coronavirus State and Local Fiscal Recovery Funds ASSISTANCE LISTING NUMBER: 21.027 YEAR(S): 2025 FEDERAL AGENCY: Department Of Treasury PASS‐THROUGH AGENCIES: State of Oregon and Multnomah County Criteria – Allowability of costs should be adequately documented in accordance with 2 CFR 200.403bullet point (g) Condition/Context – From an allowable cost sample of 60 selections, 2 selections were duplicated. Upon further investigation to quantify the error we noted expenses totaling $74,808 of non-payroll expenses were duplicated and improperly submitted for reimbursement. The associated indirect cost of $19,076 was also duplicated. Accordingly, total expenses that were subjected to the duplication error for the grant program was $93,884. Cause – When accumulating expenses for reimbursement management did not realize that they captured the same expense twice across the adjacent months. Effect - Unallowed or duplicate costs may be charged to the federal award without being identified by management. Questioned Cost - $93,884 Recommendation - Management should design and implement a control that prevents the duplication of expenses from being submitted for reimbursement. View of Responsible Officials - See Corrective Action Plan.

FINDING 2025‐004— REPORTING — MATERIAL WEAKNESS IN INTERNAL CONTROLS OVER COMPLIANCE AND NONCOMPLIANCE FEDERAL PROGRAM: Coronavirus State and Local Fiscal Recovery Funds ASSISTANCE LISTING NUMBER: 21.027 YEAR(S): 2025 FEDERAL AGENCY: Department Of Treasury PASS‐THROUGH AGENCIES: State of Oregon and Multnomah County Criteria - The contract JOHS-SVCSGEN-14303-2023 that is passed through the Multnomah County and the contract CVI-2023-The Salvation Army Medford-00069 that is passed through the state of Oregon have various annual, quarterly, and monthly reporting requirements that contain both financial and non-financial (performance) information. Condition/Context - The JOHS-SVCSGEN-14303-2023 contract required the submission of: • 4 quarterly performance reports during the fiscal year. Management could not provide evidence that any of the performance reports were prepared, reviewed or submitted to the grantor. • Monthly invoices are due at the end of the following month. All 9 reports (100% of the population) were properly reviewed, and 5 reports were submitted to the grantor after the submission deadline. • The annual equity plan report. Management provided the prepared report, however, could not provide evidence that the report was reviewed or submitted to the grantor. The CVI-2023-The Salvation Army Medford-00069 contract required the submission of: • The annual CVI Statistical Report and the CVI End-of-Grant Report. Management could not provide evidence that these reports were prepared, reviewed or submitted to the grantor. • 2 quarterly project status reports. Management provided both reports, but one report did not have evidence of a review nor proof of submission to the grantor. • Quarterly submissions of a CVI Financial/Expenditure Report. Out of a sample of 2 reports, no issues were noted. Cause - Management did not have appropriate controls that were operating effectively to ensure the reports were reviewed and submitted to the grantor timely. Management also did not retain documentation to evidence the timely submission of certain reports. Effect - The grantor may withhold funding if timely report submissions are not received in accordance with the grant agreement. Questioned Cost - Not Applicable Recommendation - Management should design and implement a control that ensures reports are reviewed and submitted in a timely manner. Further, management should retain documentation to evidence the preparation and submission of all reports. View of Responsible Officials - See Corrective Action Plan