Finding Text
Review of Drawdown Requests
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program: Continuum of Care Program
Assistance Listing Number: 14.267
Award Period: July 1, 2023, to June 30, 2024
Type of Finding: Significant Deficiency of Internal Control over Major Federal Program
Condition and Criteria: Supportive Housing Communities, Inc. can spend no more than 10 percent of its grants on administrative costs. Additionally, the Organization must match no less than 25% of all grant funds, except for leasing funds. Compliance with these requirements is reviewed when the drawdown requests are made. There is no documentation of both the preparer and reviewer signing off on the supporting documents, to ensure these steps are completed by two different individuals.
Cause: Supportive Housing Communities, Inc. requires a review of the drawdown requests by the Organization, but there is no policy requiring documentation of the separate preparation and review.
Effect: It is possible review is not completed and errors are not caught and corrected timely.
Recommendation: We recommend that management implement a policy that both the preparer and reviewer (two separate individuals) of the drawdown requests document each of their sign offs upon completion of their process, including review of the matching requirement.
View of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. Supportive Housing Communities, Inc. has updated their process to ensure that the preparer of the reimbursement and match documentation will be a different person than the person who draws down funds from the ELOCCS system. The preparer will sign and date the reimbursement packet that is presented to the finance staff for review prior to draw down. A separate person will approve the reimbursement packet and will draw down funds from the ELOCCS system.
Name of the Contact Person Responsible for the Corrective Action: Laura Caldwell, President and Chief Executive Officer
Planned Completion Date for the Corrective Action Plan: July 15, 2025