Finding Text
Federal Program Information: Assistance Listing Number (ALN): 14.251 Federal Program Name: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Federal Agency: U.S. Department of Housing and Urban Development Passed-through Entity: Not applicable Federal Award Number: B-23-CP-CA-0189 Federal Award Year: 12/29/2022 - 8/31/2031 Compliance Requirement: Period of Performance Criteria or Specific Requirements: Pursuant to 2 CFR 200.309, Modifications to period of performance, and 200.403(h), Factors affecting allowability of costs, non-federal entities may charge to a federal award only allowable costs incurred during the approved period of performance. Costs incurred outside the period of performance are not allowable unless specifically authorized by the federal awarding agency or pass-through entity. LYRIC’s grant agreement with HUD establishes the period of performance as commencing from the grant execution date (February 15, 2024) to August 31, 2031. In addition, the Program Funding Grant Guide allows reimbursement of certain pre-award costs incurred before the grant execution date, provided such soft costs are incurred on or after December 29, 2022. Condition: During the audit, we noted that LYRIC billed and requested reimbursement for expenditures totaling $116,043 that were incurred before December 29, 2022. Questioned Costs: $116,043 Cause: Due to the operational disruptions and challenges arising from the COVID-19 pandemic when the grant was approved, LYRIC did not have an effective review process to ensure federal expenditures were incurred within the approved period of performance before submitting requests for reimbursement. Effect: This resulted in questioned costs and potential repayment to the granting agency. This condition also increases the risk of noncompliance with federal requirements and may expose LYRIC to additional oversight, sanctions, or other corrective actions by the awarding agency. Recommendation: We recommend that management strengthen internal controls over grant expenditures and reimbursement to ensure that only costs incurred within the allowable period of performance are charged to the federal grant. This should include procedures to verify that expenditure dates are within the grant period prior to recording and submitting costs for reimbursement. LYRIC should request prior approval from the awarding agency if it intends to charge costs beyond the allowable period of performance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding. LYRIC will implement the following corrective actions: (1) document the start and end period of grant and performance for each future federal award in a centrally accessible grant file, and require Finance staff to reference these dates during all expense coding and reimbursement processing; (2) add a pre-submission checklist step requiring staff to confirm that all expenditure dates fall within the approved period of performance before any draw request is finalized; (3) assign supervisory review responsibility to the Finance or Grants Manager to provide a secondary check on period eligibility before submission; (4) work with HUD to assess the questioned costs and take appropriate corrective action to substitute other legitimate expenses as necessary; and (5) train finance and program staff on period of performance rules and the requirement that only costs incurred within the approved grant period may be charged to a federal award. Responsible Official and Position: Ana Rubio, Director of Finance, and Laura Chavez, Contracts Manager Expected Implementation Date: July 1, 2026