Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Significant Deficiency, Nonmaterial Noncompliance – Period of Performance
Finding 2024-002
Criteria: Period of performance is defined in 2 CFR 200.1 as “the time interval bet...
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Significant Deficiency, Nonmaterial Noncompliance – Period of Performance
Finding 2024-002
Criteria: Period of performance is defined in 2 CFR 200.1 as “the time interval between the start and end date of a federal award, which may include one or more budget periods.”
Condition: For one award, the 2023 grant award project was not closed timely in the general ledger system and the County erroneously recorded fiscal year 2024 grant costs of $1,059 to the project, which was beyond the approved period of performance of the award.
Additionally, for one award, the County recorded grant costs of $28,685 to the project, which was beyond the approved period of performance of the award.
Effect: By not having the grant project codes properly closed at the end of the period of performance, the County could potentially request reimbursement for costs incurred and recorded beyond the grants approved period of performance from the Federal government.
Questioned Costs: $29,744
Cause: The County did not have a formal policy to ensure grant project codes were properly closed and expenditures were not being recorded beyond the grant award’s stated period of performance.
Recommendation: We recommend the County should implement a formal policy to ensure all grants are properly closed and no costs are incurred on grants after their period of performance.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See below Corrective Action Plan prepared by the County.
Following the end of grant term, June 30th, Shelter Plus Care (SPC) program will ensure all final payments are made out of the grant by mid-August to ensure timely reconciliation.
• Grant Management /Revenue Reimbursement Team will send final draw for review and approval by SPC Supervisor and upon confirmation, email communication will be made with Accountant III (within the Budget Team) for final review.
• Accountant III will provide Purchase Order by Unit report (PD615) report to SPC program to ensure all POs are closed out.
• Accountant III will review PD615 report to ensure deactivation. Ongoing review will take place at least 2 months following the 90-day close-out period.
•The SPC/Finance Team will work with staff, supervisors and payroll to ensure all applicable payroll is allocated to proper (active) grant unit and respective entries are processed timely.
• When new grant is established, the SPC team will ensure that time posted and approved for SPC admin costs in PeopleSoft are for the correct grant unit/ grant fiscal period as well as ensure that funds are encumbered and paid from correct grant/grant fiscal period.
In addition to these steps, ongoing review and monitoring of grant will occur monthly during SPC’s Finance Meeting on the 4th Thursdays of the month and during the CSS Grants Meeting on the 4th Tuesdays of the month.
Completion Date: June 30, 2025
Responsible Person(s): Adia Robinson, Clinical Supervisor