Finding 1224027 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-07-20
Audit: 407437
Organization: Homeward Pikes Peak (CO)
Auditor: BIGGSKOFFORD LLP

AI Summary

  • Core Issue: Rents charged exceeded those for comparable units, violating 2 CFR 578.51(g).
  • Impacted Requirements: Failure to apply rent reasonableness standards led to questioned costs of $547.
  • Recommended Follow-Up: Strengthen reviews of rent assessments and ensure independent oversight for compliance and documentation.

Finding Text

Application of Rent Reasonableness Standards Significant deficiency U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ALN # : 14.267 Federal Award ID #'s: CO0083L8T042315, CO0083L8T042416, CO0110L8T042312, CO0110L8T042413, CO0061L8T042316, CO0061L8T042417. Condition: Rent was charged in excess of what was charged for other comparable units. Criteria: 2 CFR 578.51(g) requires that rents charged under the Continuum of Care Program not exceed rents currently being charged by the same owner for comparable unassisted units. Condition: Rent was charged in excess of what was charged for other comparable units. Questioned costs: $547. Context: As a result of audit procedures performed over rent reasonableness determinations, auditors identified 4 instances out of 37 clients tested in which the Organization’s rent reasonableness standard was not applied appropriately as amounts charged to the agency exceeded HPP's documentation of what was charged for other comparable units. Cause: While the Organization established controls to ensure amounts did not exceed HUD FMR's, they did not perform and maintain documentation over established rent reasonableness standards when evaluating comparable units. Effect: Amounts could be charged to the grant agreements that exceed what is charged for other comparable unassisted units, leading to questioned costs. Recommendation: Auditors recommend that management strengthen its review of rent reasonableness assessments to ensure that comparable unit data, market analyses, and approval steps support compliance with applicable program standards and documentation is maintained, and that such reviews be performed, where feasible, by an individual independent of the preparer to promote consistency and oversight. View of Responsible Official and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Finding Number: 2025-002 Application of Rent Reasonableness Standards Planned Corrective Action: 1. Rent reasonableness forms will undergo a secondary review to ensure proper comparability. 2. If the assisted unit is above those of comparable units, documentation will be made and relevant support will be retained to explain the justifiable reason to ensure no departures occur. Person Responsible for Corrective Action: Heather Ryan-Figueroa, VP of Programs and Colleen Cooper, Director of Finance. Anticipated Date of Completion: July 31, 2026.

Categories

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1224022 2025-002
    Material Weakness Repeat
  • 1224023 2025-002
    Material Weakness Repeat
  • 1224024 2025-002
    Material Weakness Repeat
  • 1224025 2025-002
    Material Weakness Repeat
  • 1224026 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $340,875
16.736 TRANSITIONAL HOUSING ASSISTANCE FOR VICTIMS OF DOMESTIC VIOLENCE, DATING VIOLENCE, STALKING, OR SEXUAL ASSAULT $152,049
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $89,039
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $28,147