Finding 1241625 (2025-001)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-11-04
Audit: 415691
Organization: Crosspurpose (CO)
Auditor: ARMANINO

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to $155,141 in contractual expenditures for the SNAP Employment and Training Program, lacking sufficient documentation to support allocation and approval processes.
  • Impacted Requirements: The Organization failed to meet federal documentation standards, including maintaining detailed records for cost allocation and obtaining necessary approvals for modifications to the Program Operator Plan.
  • Recommended Follow-Up: Enhance documentation practices to clearly outline services provided, allocation methodologies, and necessary approvals, while regularly reviewing this documentation for compliance and audit readiness.

Finding Text

Type of deficiency: Significant deficiency in internal control over compliance AL number: 10.561 AL title: Supplemental Nutrition Assistance Program Name of federal agency: U.S. Department of Agriculture Federal award/contract: FFY 2026 SNAP Employment and Training Contract No. 26 IHGA 206885 Repeat finding: No Criteria: In accordance with 2 CFR §§ 200.403, 200.404, and 200.405, costs charged to a federal award must be adequately documented, necessary and reasonable for the performance of the federal award, and allocable to the federal award. In addition, the Statement of Work requires the Program Operator to provide supporting documentation upon request, comply with the Department-approved Employment First Program Operator Plan, and obtain Department approval for changes or adjustments to the approved Program Operator Plan. Recipients are required to maintain documentation sufficient to support the nature, allowability, allocation, and period of performance of expenditures charged to federal programs. Condition: During our audit procedures, we noted that the Organization charged $155,141 of contractual expenditures to the FFY 2026 SNAP Employment and Training Program. The contractual expenditures consisted primarily of technology, operational, consulting, and program-support services provided through various third-party service providers and contractors. During our testing, we noted that while the Organization maintained invoices and supporting records for these expenditures, documentation was not maintained in sufficient detail to fully demonstrate the basis used to allocate certain contractual costs to the federal program, the methodology used to determine the benefit received by the program, and whether certain charges were supported by timeand- effort records, utilization metrics, or other documentation demonstrating the relationship of the expenditures to services provided under the federal award. Certain contractual expenditures identified during the State's review related to contractors or service arrangements that were not reflected in the approved Employment First Program Operator Plan. Management submitted a plan at the beginning of the contract with the Department, however they did not maintain documentation demonstrating whether selected contractors were communicated to or approved by the Department as modifications to the approved Program Operator Plan.Condition (continued): The Colorado Department of Human Services identified similar concerns during its fiscal management evaluation. The Department approved invoices and reimbursed for these costs, and did not communicate issues until the fiscal management evaluation was conducted. As a result of the State's determination and the uncertainty surrounding the ultimate resolution of the matter, management has recorded a liability associated with the expenditures identified by the State pending final resolution. Cause: The Organization maintained documentation supporting contractual expenditures charged to the program; however, controls were not operating effectively to ensure sufficient documentation was retained to support allocation methodologies for charging certain contractual expenditures to the federal award, utilization measures, and any required approvals associated with modifications to the approved Program Operator Plan. Possible effect: Without sufficient supporting documentation, the Organization may be unable to fully demonstrate that contractual expenditures charged to the federal award were necessary, reasonable, allocable, and supported by appropriate methodologies. In addition, the Organization may be unable to demonstrate compliance with requirements relating to approval of modifications to the Program Operator Plan. As a result, expenditures charged to the federal program may be challenged by oversight agencies and may be subject to disallowance or repayment. Management has recorded a liability associated with the amounts identified by the Colorado Department of Human Services pending final resolution of the matter. Questioned cost: 155,141 Recommendation: We recommend the Organization enhance documentation supporting contractual expenditures charged to federally funded programs. Documentation should clearly identify the services provided, the relationship of those services to the federal program, the methodology used to allocate costs to the program, and the basis used to demonstrate that expenditures are necessary, reasonable, and allocable to the federal award. Management should also retain documentation supporting any required Department approvals associated with modifications to the approved Program Operator Plan. Supporting documentation should be retained and periodically reviewed to ensure it is available for future monitoring, compliance, and audit activities.SECTION III - SUMMARY OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (continued) Views of responsible officials: The Organization has implemented a revised cost allocation plan in accordance with federal cost principles to determine the allocable amount of costs. The Organization aims to serve all “neighbors” regarding the mission of serving Denver neighborhoods, regardless of eligibility for government benefits. This results in challenges to directly tie certain costs to eligible participants served. As a result, the Organization has determined a cost pool that will apply a rate based on eligible participants out of total participants served as this data is tracked and readily available to help serve as a reasonable basis to allocate costs. In addition to this revised cost allocation plan, the Organization has implemented a process to review contractors being charged to its grants and ensure that these have gone through the appropriate approval processes prior to submitting for reimbursement.

Corrective Action Plan

Finding 2025-001 AL number: 10.561 AL title: Supplemental Nutrition Assistance Program Federal award or contract: FFY 2026 SNAP Employment and Training Contract No. 26 IHGA 206885 Questioned costs: $155,141 During the audit, the Organization reported $155,141 of contractual expenditures under the FFY 2026 SNAP Employment and Training Program. The expenditures primarily related to technology, outsourced IT support, operations, consulting, and other program support provided by third-party service providers and contractors. The Organization retained invoices and supporting records, but the documentation did not provide enough detail to demonstrate how certain contractual costs were allocated to eligible participants of the federal program, and whether time-and-effort records, utilization metrics, or other records supported the charges. Management submitted an Employment First Program Operator Plan to the Department at the beginning of the contract including the estimated contractual costs, but did not retain documentation showing whether the selected contractors were communicated to or approved by the Department as modifications to the approved plan. The Department had approved invoices and reimbursed these costs before raising concerns during its fiscal management evaluation. Management recorded a liability for the amounts identified by the State pending final resolution. Corrective Action Plan CrossPurpose has implemented a revised cost allocation plan consistent with federal cost principles. Because the Organization serves people throughout Denver neighborhoods regardless of eligibility for government benefits, certain shared costs cannot always be tied directly to eligible participants. The revised plan pools those costs and allocates them based on eligible participants as a proportion of total participants served, using participant data the Organization already tracks. CrossPurpose has also implemented a process to review contractors whose costs are charged to grants and confirm that each contractor has completed the applicable approval process required by the grant before reimbursement requests are submitted. Anticipated completion date: August 1, 2026

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1241626 2025-002
    Material Weakness Repeat
  • 1241627 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $274,614
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $83,750
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $58,995
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $21,260