Finding 1223504 (2025-011)

Material Weakness Repeat Finding
Requirement
H
Questioned Costs
-
Year
2025
Accepted
2026-07-09

AI Summary

  • Core Issue: GHURA charged $15,860 in costs to federal awards outside the approved budget periods, violating compliance requirements.
  • Impacted Requirements: Expenditures must only occur within the designated period of performance for federal awards, which GHURA failed to monitor effectively.
  • Recommended Follow-Up: Implement stronger monitoring controls and a tracking system for payroll and expenditures to ensure compliance with budget timelines.

Finding Text

Finding No.: 2025-011 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.267 Continuum of Care Program Federal Award No.: GU044L9C002300, GU00377L9C002302, GU0044L9C02300, GU0026L9C002305, GU0011L9C002314 Area: Period of Performance Criteria or specific requirement (including statutory, regulatory or other citation): A recipient may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Conditions: 1. Out of eight expenditures tested totaling $15,536 from a population of $48,657 (out of total expenditures of $1,053,179), four items (50%) were charged to the federal award prior to the start of the approved period of performance. Federal Award No. Payroll Pay period Ended Pay Check date POP Start Date Expenditures Questioned Costs GU0044L9C002300 11/16/24 11/22/24 12/01/24 $1,961 $1,961 GU0044L9C002300 11/02/24 11/08/24 12/01/24 1,697 1,697 GU0044L9C002300 11/02/24 11/08/24 12/01/24 4,072 4,072 GU0044L9C002300 10/19/24 10/25/24 12/01/24 3,455 3,455 $11,185 $11,185 2. Out of 40 manual adjustment transactions tested totaling $56,036 from a population of $218,515 (out of total expenditures of $1,053,179), three items (8%) were manually transferred and charged to the federal award prior to the start of the approved period of performance. Federal Award No. Payroll Pay period Ended Pay Check date POP Start Date Expenditures Questioned Costs GU0037L9C002302 10/19/24 10/25/24 01/01/25 $ 54 $ 54 GU0044L9C002300 11/16/24 11/22/24 12/01/24 824 824 GU0044L9C002300 10/05/24 10/11/24 12/01/24 2,917 2,917 $3,795 $3,795 Finding No.: 2025-011, continued Conditions, continued: 3. Out of 40 manual adjustment transactions tested totaling $56,036 from a population of $218,515 (out of total expenditures of $1,053,179), one item (3%) was manually transferred and charged to a federal award after the approved period of performance ended: Federal Award No. Payroll Pay period Ended Pay Check date POP End Date Expenditures Questioned Costs GU0011L9C002314 10/16/24 08/01/25 09/30/23 $ 837 $ 837 $ 837 $ 837 4. Out of 38 transactions tested totaling $294,156 from a population of $493,625 (out of total expenditures of $1,053,179), one item (3%) was charged to the federal award after the approved period of performance. Federal Award No. Payroll Pay period Ended Pay Check date POP End Date Expenditures Questioned Costs GU0026L9C002305 06/14/25 06/20/25 12/31/24 $ 43 $ 43 $ 43 $ 43 Cause: The GHURA Community Planning Division did not implement adequate monitoring controls to ensure compliance with period of performance requirements. GHURA’s internal control policies and procedures are not sufficiently designed to ensure the timely reclassification and liquidation of obligations within the budget period. Effect or potential effect: GHURA is in noncompliance with applicable period of performance requirements. Questioned costs: $15,860 Identification as a repeat finding: Not applicable. Finding No.: 2025-011, continued Recommendation: Responsible personnel should enforce monitoring controls to ensure compliance with period of performance requirements. The GHURA Community Planning Division should implement formal controls, including standardized timelines and a tracking system for payroll reclassifications and expenditure processing, to prevent the accumulation of unprocessed reimbursements. Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: The finding is sustained as the condition existed during the audit period and was only corrected after management identified the issue completed the corrective reclassification in the subsequent fiscal year.

Corrective Action Plan

Finding #2025-011 14.267 Continuum of Care Period of Performance Views of Responsible Officials and Planned Corrective Action Management’s Position: Condition 1, 2, & 4 Management concurs with the finding. The questioned cost relates to a payroll charge that was initially assigned to a subsequent CoC Planning Grant during the payroll reimbursement process because funding was available under that grant after the prior funding source had been exhausted. During the drawdown review, management identified that the pay period occurred prior to the start of the grant’s period of performance and therefore was not eligible to be charged to that federal award. Upon identification of the issue, the payroll cost was excluded from the reimbursement request and was not included in a federal drawdown. The appropriate corrective action was to reclassify the expense from the CoC Planning Grant to a local funding source. However, at the time the issue was identified, the accounting staff responsible for overseeing payroll reimbursements and related accounting adjustments were in the process of transitioning responsibilities. As a result, while the ineligible cost was not reimbursed with federal funds, the required accounting reclassification was not completed until the subsequent fiscal year. Corrective Actions: Management has strengthened and formalized its payroll reimbursement review procedures to ensure that grant period-of-performance requirements are verified prior to classification of payroll expenses. Management has also established procedures for documenting and tracking identified exceptions to ensure that required accounting adjustments are completed timely and reviewed by supervisory personnel. The RPE Accounting Department will be responsible for ensuring payroll reimbursement classifications are reviewed for compliance with applicable grant period-of-performance requirements. Accounting personnel responsible for payroll reimbursements and related accounting adjustments will maintain documentation of identified exceptions and ensure required adjustments are completed and reviewed by supervisory personnel. Condition 3 Management does not concur with the finding. Explanation of Disagreement: The Manual Journal Voucher (MJV) referenced by the auditor reflects a reclassification of payroll costs between federal grants. While the payroll expenditure relates to a pay period ending June 14, 2025, the expenditure was not ultimately charged to the grant with a period of performance ending December 31, 2024. The purpose of the MJV was to remove the payroll expenditure from the original grant and reclassify it to the appropriate federal grant. The corresponding entry within the same journal voucher charged the expenditure to a grant whose period of performance encompassed the payroll pay period. As a result, the payroll expenditure was not charged to a federal award outside of its period of performance. Management believes the exception resulted from reviewing only one side of the reclassification entry rather than the complete transaction. The supporting MJV demonstrates that the expenditure was removed from the grant with the expired period of performance and reassigned to the appropriate federal award. Accordingly, management respectfully requests reconsideration of this exception. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: Condition 1, 2, & 4 The enhanced payroll reimbursement review procedures and exception tracking procedures have been implemented.

Categories

Period of Performance Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management HUD Housing Programs

Other Findings in this Audit

  • 1223495 2025-002
    Material Weakness Repeat
  • 1223496 2025-003
    Material Weakness Repeat
  • 1223497 2025-004
    Material Weakness Repeat
  • 1223498 2025-005
    Material Weakness Repeat
  • 1223499 2025-006
    Material Weakness Repeat
  • 1223500 2025-007
    Material Weakness Repeat
  • 1223501 2025-008
    Material Weakness Repeat
  • 1223502 2025-009
    Material Weakness Repeat
  • 1223503 2025-010
    Material Weakness Repeat
  • 1223505 2025-012
    Material Weakness Repeat
  • 1223506 2025-013
    Material Weakness Repeat
  • 1223507 2025-014
    Material Weakness Repeat
  • 1223508 2025-015
    Material Weakness Repeat
  • 1223509 2025-016
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $51.89M
14.248 COMMUNITY DEVELOPMENT BLOCK GRANTS SECTION 108 LOAN GUARANTEES $11.31M
14.850 PUBLIC HOUSING OPERATING FUND $7.24M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $5.62M
14.872 PUBLIC HOUSING CAPITAL FUND $4.19M
14.U01 EMERGENCY HOUSING VOUCHER $1.55M
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $1.14M
14.267 CONTINUUM OF CARE PROGRAM $1.05M
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $623,030
14.879 MAINSTREAM VOUCHERS $479,687
14.225 COMMUNITY DEVELOPMENT BLOCK GRANTS/SPECIAL PURPOSE GRANTS/INSULAR AREAS $429,662
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $245,283
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $180,272
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $79,730
14.191 MULTIFAMILY HOUSING SERVICE COORDINATORS $68,838
14.275 HOUSING TRUST FUND $33,902
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $16,106