Finding 1148146 (2024-001)

Program: Continuum of Care Program (ALN 14.267) Federal Agency: U.S. Department of Housing and Urban Development Criteria: According to 24 CFR § 578.59 and the applicable Compliance Supplement for the Continuum of Care (CoC) Program, no more than 10 percent of any grant awarded may be used to pay for administrative costs. Administrative costs include those related to general management, oversight, coordination, and training on CoC program requirements. These costs must be monitored carefully to ensure compliance with federal earmarking limits. Costs for CoC planning activities and Unified Funding Agency (UFA) costs are excluded from this limit. Condition: During our audit, we noted that in some instances slightly more than 10% of the funds awarded were charged to administrative costs. These excess charges exceeded the federal limit established for administrative expenditures under the CoC program. Cause: Although administrative costs are tracked separately, the cumulative amount charged was not flagged as exceeding the 10% limit during the review process. This appears to have been an oversight in monitoring controls specific to earmarking compliance. Effect: The administrative charges exceeding the 10% cap could be viewed as inconsistent with federal program requirements. While the financial impact appears limited, strengthening monitoring in this area will help maintain compliance and avoid potential issues in future audits or funding reviews. Questioned Costs: None noted. Context: This issue was identified during our review of compliance with earmarking requirement across multiple CoC grants. While not systemic across all contracts, the occurrence of charges exceeding the allowable threshold highlights the need for improved internal controls around earmarking compliance. Repeat Finding: No Recommendation: To ensure compliance with federal earmarking requirements, we recommend that the organization implement more robust internal monitoring procedures for administrative costs charged to CoC grants. Views of Responsible Officials: See Corrective Action Plan.