Finding 1181989 (2021-007)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2021
Accepted
2026-03-23

AI Summary

  • Core Issue: The organization failed to provide necessary documentation to prove compliance with eligibility requirements for the VA Homeless Providers Grant.
  • Impacted Requirements: Non-compliance with 2 CFR 200.337 and 2 CFR 200.334 regarding record retention and access for audits.
  • Recommended Follow-Up: Management should ensure all participant eligibility documents are retained for at least three years and readily available for audits.

Finding Text

Federal Agency: Department of Veterans Affairs Federal Program Name: VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Federal Award Identification Number and Year: ODMH543-1095-659-CM-20 Pass-Through Agency: None Pass-Through Number(s): None Award Period: 10/1/2019 - 9/30/2021 Type of Finding: - Material Weakness in Internal Control over Compliance - Material Noncompliance (Modified Opinion) Criteria or specific requirement: In accordance with 2 CFR 200.337, the Federal agency or pass through entity, Inspectors General, the Comptroller General of the United States, or any of their authorized representatives must have the right to access any records of the recipient pertinent to the Federal awards to perform audits. In accordance with 2 CFR 200.334, the non-Federal entity must retain all Federal award records for three years from the date of submission of their final financial report. For awards renewed quarterly or annually, records must be retained for three years from the submission of their quarterly or annual financial report. In accordance with §200.334(a) the records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: During our testing, we noted the Organization was unable to provide documentation supporting that they were in compliance with the eligibility requirements under the grant agreement. Questioned costs: None Context: During our testing, records relating to program participants were unavailable. As a result, we were unable to determine if program participants met the eligibility requirements under the program. Cause: The participant records and details were unavailable. Effect: The Organization could have provided benefits to people that were ineligible under the program. Repeat Finding: No. Recommendation: We recommend that management retain all documents including evidence of participant eligibility under the program until the latter of the legally required retention period or completion of required audits and have the records available for audit. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Department of Veterans Affairs Federal Program Name: VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Recommendation: We recommend that management retain all documents including evidence of participant eligibility under the program until the latter of the legally required retention period or completion of required audits and have the records available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented enhanced record retention and documentation controls to ensure that all participant eligibility documentation, supporting records, and program files are retained in accordance with federal retention requirements and made available upon request for audit or monitoring purposes. The Organization has created standardized eligibility documentation checklists and file review procedures to ensure completeness of required records. Additionally, records are now maintained in a centralized and secure format (physical and/or electronic), with clear retention timelines and assigned staff accountability for ongoing compliance and periodic file reviews. Name(s) of the contact person(s) responsible for corrective action: Ryan Ross, Executive Director Planned completion date for corrective action plan: March 31, 2026

Categories

Eligibility Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1181987 2021-006
    Material Weakness Repeat
  • 1181988 2021-006
    Material Weakness Repeat
  • 1181990 2021-008
    Material Weakness Repeat
  • 1181991 2021-009
    Material Weakness Repeat
  • 1181992 2021-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
64.024 VA HOMELESS PROVIDERS GRANT AND PER DIEM PROGRAM $339,550
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $334,029
14.267 CONTINUUM OF CARE PROGRAM $196,327