Finding 1208273 (2025-004)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-04-21
Audit: 399300
Organization: Trilogy, Inc. (IL)

AI Summary

  • Core Issue: The organization failed to document rent reasonableness checks for some clients, leading to potential compliance risks.
  • Impacted Requirements: This finding relates to the need for effective internal controls as outlined in 2 CFR § 200.303.
  • Recommended Follow-Up: Program managers should ensure that all rent reasonableness checklists and certifications are properly completed by HUD staff.

Finding Text

Federal agency: Department of Housing and Urban Development Federal program title: Continuum of Care Program FALN Number: 14.267 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: September 1, 2023 – August 31, 2024; September 1, 2024- August 31, 2025. Type of Finding: Significant Deficiency in Internal Control over Compliance and Immaterial Noncompliance Criteria or specific requirement: 2 CFR § 200.303 requires recipients and subrecipients to establish, document, and maintain effective internal controls over Federal awards, aligned with the COSO Internal Control–Integrated Framework. Condition: The Organization could not provide documentation that certain rent reasonableness checks were done for selected clients. Questioned costs: None Context: This condition impacted three (3) of nine (9) checklists selected for testing. Cause: Oversight. Effect: The Organization could pay rent on behalf of a client that is 1) unreasonable in relation to rents being charged in the area of comparable unassisted units or 2) in excess of the HUD-determined fair market rate. Repeat Finding: No Recommendation: We recommend program managers verify that rent reasonableness checklists and certifications are fully completed by HUD staff. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Special Tests and Provisions – Assistance Listing No. 14.267 Recommendation: We recommend program managers verify that rent reasonableness checklists and certifications are fully completed by HUD staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement a supervisory review process requiring program managers to review and formally sign off on rent reasonableness checklists and certifications. Staff will receive refresher training on completion requirements, and management will periodically review files to ensure documentation is complete and properly approved. Name(s) of the contact person(s) responsible for corrective action: Jamie Rotter Planned completion date for corrective action plan: 6/30/2026

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 1208271 2025-002
    Material Weakness Repeat
  • 1208272 2025-003
    Material Weakness Repeat
  • 1208274 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $1.82M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $300,356
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $260,442
93.150 Projects for Assistance in Transition from Homelessness $199,874
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $158,509
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $134,641