Finding 1217652 (2023-006)

Material Weakness Repeat Finding
Requirement
G
Questioned Costs
-
Year
2023
Accepted
2026-06-16

AI Summary

  • Core Issue: The organization lacks adequate controls for monitoring federal grant compliance, financial management, and SEFA reporting.
  • Impacted Requirements: Missing documentation for matching contributions, inadequate policies for administrative cost monitoring, and improper posting of expenditures outside grant periods.
  • Recommended Follow-Up: Establish formal tracking mechanisms, implement written policies for monitoring, and conduct documented reviews of transactions and SEFA accuracy.

Finding Text

The organization did not maintain adequate controls over federal grant compliance monitoring, grant financial management, and SEFA reporting. Specifically: • Management did not maintain a formal mechanism to track and document required versus actual matching contributions for the HUD CoC program, and no grant-level calculation was available to demonstrate compliance with the required 25% match requirement. • Written policies and procedures do not address monitoring of the HUD CoC administrative cost limitation. • The accounting system permitted expenditures to be posted outside the applicable grant performance periods, and no formal grant cutoff policy or review control had been established. • Management did not perform documented reviews of transactions recorded near grant period start and end dates to ensure expenditures were recorded in the proper reporting period. • The initial SEFA provided for audit was inaccurate and unsupported by adequate underlying schedules or reconciliations. • Management had not implemented a formal documented review process to evaluate whether grants and expenditures were appropriately included on the SEFA, including evaluation of a significant State-funded capital grant received during the year.

Corrective Action Plan

LARS has implemented the following controls to address each element of this finding: HUD CoC Match Tracking: A grant-level match tracking schedule has been established for the CoC program. The schedule documents required match amounts, eligible match contributions, and cumulative match-to-date, and is updated at each reporting period. The Finance Director reviews the schedule prior to each drawdown and at fiscal year-end. Administrative Cost Limitation Monitoring: Written policies and procedures have been updated to include a procedure for monitoring the HUD CoC administrative cost limitation. The Finance Director calculates the limitation at the beginning of each grant year and monitors actual administrative costs on a quarterly basis. Grant Cutoff Procedures: A written grant financial management policy has been adopted that establishes cutoff procedures for recording expenditures within applicable grant performance periods. The accounting system has been configured to flag transactions with dates outside an active grant period for Finance Director review prior to posting. SEFA Preparation and Review: A formal SEFA preparation procedure has been implemented that requires: • A reconciliation of SEFA amounts to the general ledger and underlying grant records • A documented review of all grants and funding sources including state and local grants to determine proper SEFA inclusion and reporting treatment

Categories

Reporting Subrecipient Monitoring HUD Housing Programs Period of Performance Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1217653 2023-007
    Material Weakness Repeat
  • 1217654 2023-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $574,563
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $416,705
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $186,172
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $181,311
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $89,614