Finding 1165860 (2025-001)

Material Weakness Repeat Finding
Requirement
BL
Questioned Costs
-
Year
2025
Accepted
2025-12-20

AI Summary

  • Core Issue: The Organization charged duplicate costs of $95,294 due to inadequate review of reimbursement requests.
  • Impacted Requirements: Failure to comply with 2 CFR 200.303(a) regarding effective internal controls over Federal awards.
  • Recommended Follow-Up: Implement formalized review processes and maintain tracking systems to prevent duplicate reimbursement requests.

Finding Text

Assistance Listing, Federal Agency, and Program Name - 14.905; U.S. Department of Housing and Urban Development; Lead Hazard Reduction Demonstration Program Federal Award Identification Number and Year - 252697 Pass through Entity - City of Chicago Department of Public Health Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR 200.303(a) states each recipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Questioned Costs - $95,294 Identification of How Questioned Costs Were Computed - During the period under audit there were two period-end reimbursement requests. Such requests include expenditures from the entire grant period (January 1, 2024 December 31, 2024). Expenditures on the two reimbursement requests were compared in their entirety to expenditures on reimbursement requests earlier in the year. Management determined there were total duplicate costs of $95,294. Context - Of the 25 expenditures tested for allowable costs, two contractor samples were charged in the period-end reimbursement request and in a previous reimbursement request. Subsequently the Organization evaluated the costs charged to the grant and identified contractor invoices in the amount of $95,294 that were erroneously charged to the grant and reported on the schedule of expenditures of federal awards. Cause and Effect - Timely and accurate review over period-end reimbursement requests was not performed and duplicate costs were requested for reimbursement. Recommendation - The Organization should establish formalized review processes and controls to ensure proper identification of expenditures that have been submitted for reimbursement. Views of Responsible Officials and Corrective Action Plan - The Organization agrees with recommendation. Beginning May 1, 2025, the CFO maintains a payout tracker which is updated every time a vendor payout is made and tracks that payment to the reimbursement request and the final payment by the pass-through agency. This process ensures that a payout is not included in a payout request multiple times. The Staff Accountant also maintains a tracker of all reimbursement requests to track with the program budgets and for inclusion in the MIP accounting system. In addition, new personnel are involved in the process with a more formal approval and authorization process implemented. The Organization’s staff has communicated these duplicate requests to the appropriate personnel at the granting agency and are coordinating the repayment of the excess funds as determined by the granting agency.

Corrective Action Plan

Condition: The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Planned Corrective Action: The CFO maintains a payout tracker which is updated every time a vendor payout is made and tracks that payment to the reimbursement request and the final payment by the pass-through agency. This process ensures that a payout is not included in a payout request multiple times. The Staff Accountant also maintains a tracker of all reimbursement requests to track with the program budgets and for inclusion in the MIP accounting system. In addition, new personnel are involved in the process with a more formal approval and authorization process implemented. The Organization’s staff has communicated these duplicate requests to the appropriate personnel at the granting agency and are coordinating the repayment of the excess funds as determined by the granting agency. Contact person responsible for corrective action: Tom Sakos, Chief Financial Officer, and Jenny Cuitiva, Accounting Manager Anticipated Completion Date: May 1, 2025 for implementing controls and November 30, 2025 for communicating with the granting agency.

Categories

Allowable Costs / Cost Principles Cash Management Material Weakness Reporting

Programs in Audit

ALN Program Name Expenditures
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $2.88M
21.024 COVID-19 - COMMUNITY DEVELOPMENT FINANCIAL INSTITUTIONS RAPID RESPONSE PROGRAM (CDFI RRP) $639,193
21.026 COVID-19 - HOMEOWNER ASSISTANCE FUND $90,735
14.905 LEAD HAZARD REDUCTION DEMONSTRATION GRANT PROGRAM $69,964
14.169 HOUSING COUNSELING ASSISTANCE PROGRAM $44,650