Finding 1148037 (2024-002)

Finding 2024‐002 Significant deficiency in internal controls over compliance related to allowable costs/cost principles compliance requirement. Federal Agency: Department of Treasury Program Title: Community Development Financial Institutions Fund Equitable Recovery Program (CDFI ERP) Federal Assistance Listing Number: 21.033 Award Number: 22ERP061530 Award Period: April 10, 2023 through December 31, 2028 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E require that personnel expenses allocated both directly and indirectly to federal awards be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, properly allocated and supported by adequate documentation based on an after the fact determination. Condition/Context for Evaluation During the year ended December 31, 2024, allocations of compensation expenditures were supported by a predetermined allocation created by a supervising manager responsible for overseeing all employees working on federally funded grants. The internal control system did not include a documented after the fact review of the actual activity conducted by the employee. Effect or Potential Effect HomeSight did not fully comply with the allowable cost principles as specified in 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E, Section 200.430. As a result, there may be charges to awards that do not have adequate allocation support. Questioned Costs Not determinable - HomeSight records lack established procedures of a documented after-the-fact level of activity. Accordingly, it is impossible to determine if there is a variance from pre-determined allocation levels. Cause HomeSight’s internal controls did not ensure that employees time allocated to federal awards was supported by adequate documentation. Repeat Finding Not a repeat finding. Recommendation We recommend that HomeSight implement the necessary internal control that includes processes to perform periodic after-the-fact reviews of charges made to a Federal award based on pre-determined allocation rates. View of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.