Finding 1190779 (2025-004)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-03-27

AI Summary

  • Core Issue: The Alliance failed to fulfill its monitoring responsibilities for subawards under the Continuum of Care Program, including proper identification and compliance checks.
  • Impacted Requirements: Key requirements not met include clear subaward documentation, monitoring subrecipient activities, and verifying necessary audits.
  • Recommended Follow-Up: Assign knowledgeable staff to oversee subawards and ensure compliance with federal regulations and reporting requirements.

Finding Text

2025-004: Subrecipient Monitoring (Continued) Condition and context: In relation to Continuum of Care Program (AL # 14.267), the Alliance did not complete the required monitoring responsibilities, specifically: 1. Ensuring that every subaward is clearly identified to the subrecipient as a subaward, which is required to include Federal award identification, requirements of the subaward, any additional requirements imposed, indirect cost rate detail, a requirement that subrecipient permit the pass-through entity and auditors to access the subrecipient’s records and financial statements for the pass-through entity to fulfill its monitoring requirements and appropriate terms and conditions concerning the closeout of the subaward. There were no subaward contracts for the period October 1, 2023 to September 30, 2024. Subaward contracts for the period October 1, 2024 to September 30, 2025 did not include all required items. 2. Monitoring the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward including: Reviewing financial and performance reports, ensuring that the subrecipient takes corrective action on all significant developments that negatively affect the subaward, issuing a management decision for audit findings pertaining only to the Federal award, and resolving audit findings specifically related to the subaward. The subrecipient received a significant deficiency and compliance finding in their June 30, 2024 single audit noting that there was no rent calculation worksheet present for one of the individuals tested to indicate income in order to ensure program income portions are being appropriately calculated. The Alliance did not obtain the single audit report, nor resolve the finding specifically related to the subaward. As such, there were limited indications that the Alliance monitored the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. 3. Verifying that a subrecipient is audited as required by CFR, which the Alliance did not verify. Cause: The cause is due to limited internal controls related to subrecipient monitoring Effect or potential effect: Without adequate controls over this process, the subrecipient may not be complying with Federal statutes, regulations, and the terms and conditions of the subaward. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable Recommendation: The Alliance must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all subawards to ensure that the Alliance has met the applicable compliance and reporting requirements of each federal award. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Corrective Action Plan

As of September 2025, the Continuum of Care program was placed under the responsibility of the Director of Program Services, Quinn Lee, who has extensive experience managing housing programs in her previous employment, including federal programs. She is currently working to respond to the audit findings and rebuild the appropriate agreements and documentation with sub-awardees to meet the requirements. It must be noted that HUD has entered into legal action to make significant changes to this program which may affect how the Alliance is required to respond in the future.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1190778 2025-003
    Material Weakness Repeat
  • 1190780 2025-005
    Material Weakness Repeat
  • 1190781 2025-002
    Material Weakness Repeat
  • 1190782 2025-002
    Material Weakness Repeat
  • 1190783 2025-002
    Material Weakness Repeat
  • 1190784 2025-002
    Material Weakness Repeat
  • 1190785 2025-002
    Material Weakness Repeat
  • 1190786 2025-003
    Material Weakness Repeat
  • 1190787 2025-003
    Material Weakness Repeat
  • 1190788 2025-003
    Material Weakness Repeat
  • 1190789 2025-003
    Material Weakness Repeat
  • 1190790 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $280,798
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $179,931
93.917 HIV CARE FORMULA GRANTS $46,872
93.941 HIV DEMONSTRATION, RESEARCH, PUBLIC AND PROFESSIONAL EDUCATION PROJECTS $18,724
93.153 COORDINATED SERVICES AND ACCESS TO RESEARCH FOR WOMEN, INFANTS, CHILDREN, AND YOUTH $14,256
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $13,894