Finding Text
2024-009 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 2023-013. Recommendation: In order to prevent future occurrences of this deficiency, RBT recommends 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.