Finding Text
Federal Agencies: Department of Housing and Urban Development
Federal Assistance Listing Numbers: 14.267
Program: Continuum of Care
Award/Pass-Through Entity Identifying Numbers: 202212-01122
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable
costs resulting from obligations incurred during the funding period and any pre-award costs
authorized by the federal awarding agency. Unless the federal awarding agency authorizes an
extension, a recipient shall liquidate all obligations incurred under the award no later than
90 calendar days after the funding period or the date of completion as specified in the terms and
conditions of the award or in agency implementing instructions.
Condition: LifeWire allocated expenditures that were incurred prior to the start of the funding
period. During our testing of costs, we noted that one of the 60 samples selected for testing was
incurred prior to the start of the applicable funding period and was not approved in accordance
with §200.308.
Cause: LifeWire did not have policies and procedures in place to ensure that costs were only charged
as incurred during the appropriate funding period.
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and
reimbursable, including controls over review of the date of incurrence, LifeWire could incorrectly
charge expenditures to the federal programs.
Questioned Costs: Below reporting threshold.
Context: This is a condition identified per review of LifeWire’s compliance with specified requirements
not using a statistically valid sample. Expenses in the first month of the grant period in 2023 were
$63,132, with total expenses in 2023 of $358,191.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that only costs incurred during the appropriate funding period be
charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management agrees with the finding that policies and procedures
were not properly in place to ensure costs were only charged as incurred during the funding period.
Management modified its policies and procedures to obtain detailed clarification for period-end
items from the contract manager ensuring properly included for reimbursement.