Finding 1225247 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-07-31
Audit: 408287
Organization: Rebuilding Together, Inc. (DC)
Auditor: APRIO LLP

AI Summary

  • Core Issue: SF-425 reports lacked required matching contributions, leading to incomplete financial reporting.
  • Impacted Requirements: Non-compliance with 2 CFR §200.328, which mandates accurate reporting of both federal and matching funds.
  • Recommended Follow-Up: Implement procedures for accurate SF-425 reporting, establish controls for tracking matching contributions, and ensure supervisory review before submission.

Finding Text

Reportable Finding Considered a Significant Deficiency – Reporting Matching Agency: Department of Housing and Urban Development Program: Rural Capacity Building for Community Development and Affordable Housing Grants ALN# 14.265 Program Year: 2025 Criteria: 2 CFR §200.328 requires that recipients submit financial reports using OMB approved data elements, specifically the Federal Financial Report (SF-425), and such reports must be submitted as required by the Federal award and include all required financial information. The SF-425 is designed to report the cumulative federal share and recipient (matching) share of program expenditures. Condition: During testing of financial reporting for ALN 14.265, we noted that SF-425 reports submitted during the audit period did not include the required matching (non-federal) component. Specifically, the recipient share (matching contributions) was not reported. Cause: The condition appears to be due to inadequate understanding of SF-425 reporting requirements and lack of internal controls to ensure that matching contributions are properly included in required federal financial reports. Effect: Failure to report matching contributions on the SF-425 results in incomplete and inaccurate financial reporting to the federal awarding agency. This may impair the federal agency’s ability to monitor compliance with matching requirements and increase the risk of questioned costs or funding disallowances if matching requirements are not properly reported. Questioned costs: None Perspective: Statistical sampling was not used but sampling methodology followed AICPA guidelines. Repeat finding: This is not a repeat finding. Recommendation: We recommend management implement procedures to ensure all SF-425 reports include complete and accurate reporting of both federal and matching components. Controls should be established to track and reconcile matching contributions to supporting documentation and a supervisor should review to ensure completeness and compliance with reporting requirements prior to submission. Management’s response (unaudited): See Corrective Action Plan

Corrective Action Plan

Management has implemented enhanced procedures to strengthen the tracking, reconciliation, and reporting of recipient share (matching) contributions associated with federal awards under ALN 14.265, Rural Capacity Building for Community Development and Affordable Housing Grants. Actions include: 1. Updating the internal matching contribution tracking system to improve documentation and cumulative tracking of recipient share contributions by grant and reporting period. 2. Establishing a formal reconciliation process between supporting documentation, grant records, and amounts reported on the SF-425 to ensure both federal expenditures and applicable recipient share amounts are accurately reflected. 3. Implementing a pre-submission review checklist and control requiring verification that recipient share (matching) information has been evaluated, reconciled, and included on the SF-425, when applicable, prior to submission to the awarding agency. 4. Requiring supervisory review and approval of the completed SF-425 to confirm completeness, accuracy, and compliance with reporting requirements under 2 CFR §200.328 before certification and filing. 5. Updating internal grant reporting procedures and providing additional guidance to staff responsible for federal financial reporting regarding SF-425 reporting requirements and recipient share reporting expectations. Management will evaluate the SF-425 reports submitted during the audit period to determine whether amendments are necessary. If required, amended SF-425 reports will be submitted to accurately reflect recipient share (matching) contributions. Anticipated Completion Date: The enhanced controls were implemented during 2026 and will be operational for the preparation, review, and certification of the SF-425 for the reporting period ending June 30, 2026, and all future reporting periods. For the reports submitted before June 30, 2026, management will confirm with HUD by July 20 if they would like an amended report. If HUD request one, the amended report will be submitted by August 15. Responsible Contact: Lakia Goodman, Controller (preparation and reconciliation of recipient share reporting) Chris Perry Authorized SF-425 Signer/Certifying Official (final review and certification)

Categories

Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1225244 2025-001
    Material Weakness Repeat
  • 1225245 2025-001
    Material Weakness Repeat
  • 1225246 2025-001
    Material Weakness Repeat
  • 1225248 2025-002
    Material Weakness Repeat
  • 1225249 2025-002
    Material Weakness Repeat
  • 1225250 2025-002
    Material Weakness Repeat
  • 1225251 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.278 VETERANS HOUSING REHABILITATION AND MODIFICATION PROGRAM $231,750
14.921 OLDER ADULTS HOME MODIFICATION GRANT PROGRAM $223,198
94.006 AMERICORPS STATE AND NATIONAL 94.006 $185,669
14.906 HEALTHY HOMES TECHNICAL STUDIES GRANTS $76,561
14.265 RURAL CAPACITY BUILDING FOR COMMUNITY DEVELOPMENT AND AFFORDABLE HOUSING GRANTS $55,000
14.902 LEAD TECHNICAL STUDIES GRANTS $564