Finding Text
2023-013 Matching, Level of Effort, Earmarking
Assistance Listing No.: 14.267 Continuum of Care Program (“CoC’)
Condition: The Organization was unable to demonstrate controls over the matching and earmarking
requirements.
Criteria: The recipient or subrecipient must match all grant funds, except for leasing funds, with no
less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic
areas in which there is more than one grant agreement, the 25 percent match must be provided
on a grant-by-grant basis. Recipients that are a UFA or are the sole recipient for their
Continuum may provide match on a Continuum-wide basis (24 CFR section 578.73(a)).No more than 10 percent of any grant awarded may be used for paying costs of administering the assistance. Administrative costs include the costs associated with general management oversight, and coordination, training on the CoC program requirements, and environmental review. Administrative costs do not include costs for CoC planning activities and UFA cost (24 CRR section 578.59).
Questioned Costs There are no questioned costs.
Cause: The Organization did not have sufficient controls to ensure that the matching and earmarking
requirements were met.
Effect: It is more likely that the Organization will not meet the percent matching requirements and
earmarking since there is no formal set of controls over the requirements.
Perspective: This is a systemic issue in that controls over the requirements have not been developed to
ensure the reported information is accurate
Repeat Finding: This is a repeat finding. See finding 2022-016.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management
develop a set of controls to ensure that they are meeting 25% match and 10% earmarking
requirements.
Auditee's Response: The Organization agrees with the finding. See attached corrective action plan.