2022-009 Finding: Matching - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-20-MC-08-0005 / Award Year: 2020 Status: Corrective action complete Corrective Action: The City disagrees with the finding. To remediate prior finding 2021-009,...
2022-009 Finding: Matching - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-20-MC-08-0005 / Award Year: 2020 Status: Corrective action complete Corrective Action: The City disagrees with the finding. To remediate prior finding 2021-009, HOST and HUD Technical Assistance provider, HomeBase, created an ESG Match Guide and Reporting template and training for sub-grantees utilizing ESG funds that incorporate regulations contained within 24 CFR 576.201. HomeBase and HOST conducted a match training on July 22, 2022 with subrecipients that received funding under E-20-MC-08-0005. Documentation of the July 2022 training and copies of the ESG Match Guide were provided to BDO on August 25, 2023 as requested. The ESG Match Guide outlines the ESG Match Documentation and Timing Requirements for Cash and In-Kind Match (this includes non-cash, i.e., Property, Goods, and Equipment). HOST is executing Commitment Letters and/or Memorandums of Understanding (MOU) as required prior to executing grant contracts with subrecipients. Commitment Letters for cash match must contain: ** Amount of cash to be provided to the recipient for the project ** Specific date the cash will be made available ** The actual grant and fiscal year to which the cash match will be contributed ** Time period during which funding will be available ** Allowable activities to be funded by the cash match MOU?s for in-kind match must contain: 1. Value of donated goods to be provided to the recipient for the project 2. Specific date the goods will be made available 3. The actual grant and fiscal year to which the match will be contributed 4. Time period during which the donation will be available 5. Allowable activities to be provided by the donation 6. Value of commitments of land, buildings, and equipment ? the value of these items is one-time only and cannot be claimed by more than one project or by the same project in another year The ESG Match Report includes pertinent project information (i.e., project, HOST contract number, grant amount, the project term date, match required for the grant, match being reported and reported to date (prior cumulative). The cash match documentation required with each report submission is: ** Documentation of cash source ** Expenditure documentation that demonstrates: ** Timing of expenditure ** Shows that expenses were incurred for eligible activities This may include general ledger and other similar documentation. The in-kind match documentation required with each report submission is: ** Documentation of contribution (including time and description) ** Documentation of the valuation of the contribution ** Documentation that contribution supported eligible activities ** Documentation of service hours provided (this should be a detailed record that shows dates, hours, activities, etc.) This may include copies of employee timesheets/paychecks and other similar documentation. The report must be certified via signature with the authorized signatory. The documentation and certification requirements contained in HOST?s ESG Match Guide and ESG Match Report meet all requirements necessary including those outlined in CPD Monitoring Exhibits 28-7 (Guide for Review of ESG Match Requirements), and as applicable 28-8 (Guide for Review of ESG Financial Management and Cost Allowability), 34-1 (Guide for Review of Financial Management and Audits), and 34-2 (Guide for Review of Cost Allowability). Likewise, match requirements are reflected in HOST contractual agreements as standard language. The agreement language outlines match report submissions, and documentation and records maintenance requirements. Program Officers in HOST?s Division of Housing Stability and Homelessness Resolution (HSHR) now ensures that contractor?s submit match reports with supporting documentation and certifications as outlined in the executed agreements and per the policy guide. Person(s) Responsible for Implementing: HOST - Housing Stability and Homelessness Resolution Division Directors Implementation Date: Complete