Finding Text
Criteria: Continuum of Care Program, Assistance Listing 14.267, requires recipients and subrecipients to provide a match of no less than 25% of grant funds, excluding leasing funds, using eligible cash or in-kind contributions from non-CoC sources. Match must be supported by records sufficient to demonstrate that the contributions are eligible, properly valued, from allowable sources, and applied to the applicable grant period. In addition, 2 CFR 200.303 requires the Organization to establish and maintain effective internal control over the federal award, including controls designed to support compliance with matching requirements. Condition: During testing of both match reports submitted during the audit period, representing 100% of the population, we noted that the match calculations and supporting documentation were not consistently subject to documented independent review before submission. Specifically, the same individual participated in portions of both the preparation and review process, and evidence of a separate supervisory review was not consistently retained. No unsupported or ineligible match amounts were identified from the documentation tested; however, the review control was not operating as designed. Cause and Effect: Written procedures did not clearly assign preparation and independent review responsibilities for match reporting, and evidence of review by an individual not involved in preparing the match calculations was not consistently retained. The lack of independent review and segregation of duties increases the risk that errors, unsupported amounts, or noncompliance with matching requirements could occur and not be detected in a timely manner. No known questioned costs were identified. The audit procedures did not identify unsupported or ineligible match amounts; therefore, no likely questioned costs were identified based on the information available. Repeat Finding: This is a repeat finding related to prior-year finding 2024-005. Recommendation: We recommend that the Organization implement procedures to ensure independent review and approval of match calculations and supporting documentation prior to submission. Where segregation of duties is limited, management should implement compensating controls, such as documented secondary review by an individual not involved in preparation.