Finding Text
Finding Number: 2024-002
Finding Type:
Internal Control Over Compliance – Subrecipient Monitoring
Information on the Federal Programs:
Federal Agency: U.S. Department of Housing and Urban Development
Assistance Listing Number: 14.267
Federal Program Name: Continuum of Care Program
Federal Award Periods: October 1, 2022 – September 30, 2023
October 1, 2023 – September 30, 2024
Federal Awards: VT0081Y1T002102, VT0081Y1T002103
VT0082Y1T002102, VT0082Y1T002103
VT0083Y1T002102, VT0083Y1T002103
VT0084Y1T002102, VT0084Y1T002103
VT0085Y1T002102, VT0085Y1T002102
Federal Agency: U.S. Department of Health and Human Services
Assistance Listing Number: 93.623
Federal Program Name: Basic Center Program
Federal Award Periods: October 1, 2022 – September 30, 2023
October 1, 2023 – September 30, 2024
Federal Awards: 90CY7401-01-00
90CY7401-01-00
Criteria:
Elevate Youth Services, Inc. has the responsibility to monitor the programmatic and financial
components of any Federal grant funds that it passes through to another organization. Monitoring
activities include and are not limited to the following:
1) Establishing formal policies and procedures regarding Elevate’s approach to subrecipient
monitoring and creating tools to track and document subrecipient programmatic and financial
performance under the award.
2) Performing risk assessments of subrecipients throughout the year to identify areas of risk or
identify changes with subrecipients that could trigger compliance risks.
3) Review of programmatic and financial activities related to the awards through site visits or
desk review.
4) Formal communication to subrecipients as it relates to the results of site visits or desk
reviews and the process for necessary corrective action, when necessary.
Draft #2
ELEVATE YOUTH SERVICES, INC.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
For the Year Ended June 30, 2024
33
Section III. Federal Award Findings and Questioned Costs (continued)
Finding Number: 2024-002 (continued)
Condition Found and Context:
Elevate did not perform complete subrecipient site visits or desk reviews at either the programmatic
and financial performance level consistently during the year under audit, however the program staff
developed its approach to site visits and created tools to initiate site visits. Elevate did perform site
visits and completed exit conferences on site, however, the results of the visits have not been
formally documented or communicated to the subgrantees or to Elevate’s management.
Cause and Effect:
Elevate experienced significant staffing challenges in managing this award from the program’s
inception. While Elevate has a long experience of providing subgrants to partner organizations, the
personnel responsible for the management of this program turned over frequently enough that a
formal and consistent practice of subrecipient monitoring has not been able to be established.
This result of not performing consistent site visits and monitoring and formally communicating the
results can result in delays in identifying noncompliance or not identifying noncompliance at all.
Questioned Costs:
None
Repeat Finding:
Yes
Recommendation:
Management should prioritize the completion in formalizing its policies and procedures as it relates to
subrecipient monitoring for this program and these procedures should be consistent with other
organizational monitoring programs. These procedures should include the process and timetable in
which results will be communicated with the subgrantees and internally.
Elevate must also complete its documentation on the site visits and communicate the results of the
visits to its subgrantees and internally.
Views of Responsible Official and Corrective Action Plan
Management acknowledges and understands this finding. A response to the finding is noted in the
Corrective Action Plan on pages 38-39.