FAC Explorer

Finding 13046 (2022-009)

Material Weakness Repeat Finding
Requirement
G
Questioned Costs
-
Year
2022
Accepted
2023-09-27
Audit: 17407
Organization: City and County of Denver (CO)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: HOST's tracking form for matching contributions lacks evidence of reconciliation and review, violating internal control requirements.
  • Impacted Requirements: Non-compliance with 2 CFR Section 200.303 and 24 CFR 576.201 regarding accurate reporting and matching contributions.
  • Recommended Follow-Up: Revise the matching form to include fiscal year identification and ensure it is reviewed and signed off by a designated individual.

Finding Text

Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: HOST?s form used to track matching provided by subrecipients did not have evidence to indicate (1) numbers per the match reports were reconciled to supporting documentation provided by the subrecipient and (2) sign off to evidence review. The form also did not have a record of the fiscal year ESG grant for which the matching contribution was being made. Cause: Controls were not sufficiently designed to ensure information provided by the subrecipients was correct, and that matching requirements were met. Effect or Potential Effect: Inadequate controls over review of the match reports could result in matching requirements not being fulfilled by subrecipients in accordance with 24 CFR 576.201. Questioned Costs: None Context: A sample of four match reports was selected from a population of six. For each match report selected, there was no evidence of review of the match form for accuracy. This is a condition identified per review of the City?s compliance with specified requirements using a sample that was not statistically valid. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2021-009 in the 2021 report. Recommendation: The current matching form should be improved to identify the Federal ESG fiscal year award. The form should also include evidence it was reviewed and approved by a designated individual within HOST. Views of Responsible Officials: The City disagrees with the finding. The City has created an ESG match guide and reporting template and has provided training for subrecipients utilizing ESG funds. For additional information, see the City?s separate report for planned corrective actions.

Corrective Action Plan

2022-009 Finding: Matching - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-20-MC-08-0005 / Award Year: 2020 Status: Corrective action complete Corrective Action: The City disagrees with the finding. To remediate prior finding 2021-009, HOST and HUD Technical Assistance provider, HomeBase, created an ESG Match Guide and Reporting template and training for sub-grantees utilizing ESG funds that incorporate regulations contained within 24 CFR 576.201. HomeBase and HOST conducted a match training on July 22, 2022 with subrecipients that received funding under E-20-MC-08-0005. Documentation of the July 2022 training and copies of the ESG Match Guide were provided to BDO on August 25, 2023 as requested. The ESG Match Guide outlines the ESG Match Documentation and Timing Requirements for Cash and In-Kind Match (this includes non-cash, i.e., Property, Goods, and Equipment). HOST is executing Commitment Letters and/or Memorandums of Understanding (MOU) as required prior to executing grant contracts with subrecipients. Commitment Letters for cash match must contain: ** Amount of cash to be provided to the recipient for the project ** Specific date the cash will be made available ** The actual grant and fiscal year to which the cash match will be contributed ** Time period during which funding will be available ** Allowable activities to be funded by the cash match MOU?s for in-kind match must contain: 1. Value of donated goods to be provided to the recipient for the project 2. Specific date the goods will be made available 3. The actual grant and fiscal year to which the match will be contributed 4. Time period during which the donation will be available 5. Allowable activities to be provided by the donation 6. Value of commitments of land, buildings, and equipment ? the value of these items is one-time only and cannot be claimed by more than one project or by the same project in another year The ESG Match Report includes pertinent project information (i.e., project, HOST contract number, grant amount, the project term date, match required for the grant, match being reported and reported to date (prior cumulative). The cash match documentation required with each report submission is: ** Documentation of cash source ** Expenditure documentation that demonstrates: ** Timing of expenditure ** Shows that expenses were incurred for eligible activities This may include general ledger and other similar documentation. The in-kind match documentation required with each report submission is: ** Documentation of contribution (including time and description) ** Documentation of the valuation of the contribution ** Documentation that contribution supported eligible activities ** Documentation of service hours provided (this should be a detailed record that shows dates, hours, activities, etc.) This may include copies of employee timesheets/paychecks and other similar documentation. The report must be certified via signature with the authorized signatory. The documentation and certification requirements contained in HOST?s ESG Match Guide and ESG Match Report meet all requirements necessary including those outlined in CPD Monitoring Exhibits 28-7 (Guide for Review of ESG Match Requirements), and as applicable 28-8 (Guide for Review of ESG Financial Management and Cost Allowability), 34-1 (Guide for Review of Financial Management and Audits), and 34-2 (Guide for Review of Cost Allowability). Likewise, match requirements are reflected in HOST contractual agreements as standard language. The agreement language outlines match report submissions, and documentation and records maintenance requirements. Program Officers in HOST?s Division of Housing Stability and Homelessness Resolution (HSHR) now ensures that contractor?s submit match reports with supporting documentation and certifications as outlined in the executed agreements and per the policy guide. Person(s) Responsible for Implementing: HOST - Housing Stability and Homelessness Resolution Division Directors Implementation Date: Complete

Categories

Matching / Level of Effort / Earmarking Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 13044 2022-005
    Material Weakness Repeat
  • 13045 2022-006
    Material Weakness
  • 13047 2022-008
    Significant Deficiency Repeat
  • 13048 2022-018
    Significant Deficiency
  • 13049 2022-006
    Material Weakness
  • 13050 2022-008
    Significant Deficiency Repeat
  • 13051 2022-018
    Significant Deficiency
  • 13052 2022-010
    Significant Deficiency
  • 13053 2022-015
    Significant Deficiency Repeat
  • 13054 2022-018
    Significant Deficiency
  • 13055 2022-010
    Significant Deficiency
  • 13056 2022-015
    Significant Deficiency Repeat
  • 13057 2022-018
    Significant Deficiency
  • 13058 2022-016
    Significant Deficiency
  • 13059 2022-018
    Significant Deficiency
  • 13060 2022-014
    Significant Deficiency
  • 13061 2022-018
    Significant Deficiency
  • 13062 2022-014
    Significant Deficiency
  • 13063 2022-018
    Significant Deficiency
  • 13064 2022-018
    Significant Deficiency
  • 13065 2022-018
    Significant Deficiency
  • 13066 2022-018
    Material Weakness
  • 13067 2022-018
    Significant Deficiency
  • 13068 2022-018
    Significant Deficiency
  • 13069 2022-018
    Significant Deficiency
  • 13070 2022-011
    Significant Deficiency
  • 13071 2022-013
    Significant Deficiency
  • 13072 2022-018
    Significant Deficiency
  • 13073 2022-012
    Material Weakness
  • 13074 2022-018
    Significant Deficiency
  • 13075 2022-012
    Material Weakness
  • 13076 2022-018
    Significant Deficiency
  • 13077 2022-010
    Significant Deficiency
  • 13078 2022-015
    Significant Deficiency Repeat
  • 13079 2022-018
    Significant Deficiency
  • 13080 2022-015
    Significant Deficiency Repeat
  • 13081 2022-007
    Significant Deficiency
  • 13082 2022-012
    Material Weakness
  • 13083 2022-018
    Significant Deficiency
  • 13084 2022-010
    Significant Deficiency
  • 13085 2022-015
    Significant Deficiency Repeat
  • 13086 2022-018
    Significant Deficiency
  • 13087 2022-010
    Significant Deficiency
  • 13088 2022-015
    Significant Deficiency Repeat
  • 13089 2022-018
    Significant Deficiency
  • 13090 2022-010
    Significant Deficiency
  • 13091 2022-015
    Significant Deficiency Repeat
  • 13092 2022-018
    Significant Deficiency
  • 13093 2022-010
    Significant Deficiency
  • 13094 2022-015
    Significant Deficiency Repeat
  • 13095 2022-018
    Significant Deficiency
  • 13096 2022-010
    Significant Deficiency
  • 13097 2022-015
    Significant Deficiency Repeat
  • 13098 2022-018
    Significant Deficiency
  • 13099 2022-017
    Significant Deficiency Repeat
  • 13100 2022-018
    Significant Deficiency
  • 589486 2022-005
    Material Weakness Repeat
  • 589487 2022-006
    Material Weakness
  • 589488 2022-009
    Material Weakness Repeat
  • 589489 2022-008
    Significant Deficiency Repeat
  • 589490 2022-018
    Significant Deficiency
  • 589491 2022-006
    Material Weakness
  • 589492 2022-008
    Significant Deficiency Repeat
  • 589493 2022-018
    Significant Deficiency
  • 589494 2022-010
    Significant Deficiency
  • 589495 2022-015
    Significant Deficiency Repeat
  • 589496 2022-018
    Significant Deficiency
  • 589497 2022-010
    Significant Deficiency
  • 589498 2022-015
    Significant Deficiency Repeat
  • 589499 2022-018
    Significant Deficiency
  • 589500 2022-016
    Significant Deficiency
  • 589501 2022-018
    Significant Deficiency
  • 589502 2022-014
    Significant Deficiency
  • 589503 2022-018
    Significant Deficiency
  • 589504 2022-014
    Significant Deficiency
  • 589505 2022-018
    Significant Deficiency
  • 589506 2022-018
    Significant Deficiency
  • 589507 2022-018
    Significant Deficiency
  • 589508 2022-018
    Material Weakness
  • 589509 2022-018
    Significant Deficiency
  • 589510 2022-018
    Significant Deficiency
  • 589511 2022-018
    Significant Deficiency
  • 589512 2022-011
    Significant Deficiency
  • 589513 2022-013
    Significant Deficiency
  • 589514 2022-018
    Significant Deficiency
  • 589515 2022-012
    Material Weakness
  • 589516 2022-018
    Significant Deficiency
  • 589517 2022-012
    Material Weakness
  • 589518 2022-018
    Significant Deficiency
  • 589519 2022-010
    Significant Deficiency
  • 589520 2022-015
    Significant Deficiency Repeat
  • 589521 2022-018
    Significant Deficiency
  • 589522 2022-015
    Significant Deficiency Repeat
  • 589523 2022-007
    Significant Deficiency
  • 589524 2022-012
    Material Weakness
  • 589525 2022-018
    Significant Deficiency
  • 589526 2022-010
    Significant Deficiency
  • 589527 2022-015
    Significant Deficiency Repeat
  • 589528 2022-018
    Significant Deficiency
  • 589529 2022-010
    Significant Deficiency
  • 589530 2022-015
    Significant Deficiency Repeat
  • 589531 2022-018
    Significant Deficiency
  • 589532 2022-010
    Significant Deficiency
  • 589533 2022-015
    Significant Deficiency Repeat
  • 589534 2022-018
    Significant Deficiency
  • 589535 2022-010
    Significant Deficiency
  • 589536 2022-015
    Significant Deficiency Repeat
  • 589537 2022-018
    Significant Deficiency
  • 589538 2022-010
    Significant Deficiency
  • 589539 2022-015
    Significant Deficiency Repeat
  • 589540 2022-018
    Significant Deficiency
  • 589541 2022-017
    Significant Deficiency Repeat
  • 589542 2022-018
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance for Needy Families $20.71M
21.023 Emergency Rental Assistance Program $19.69M
20.106 Airport Improvement Program $16.78M
93.575 Child Care and Development Block Grant (ccdbg) $13.92M
93.778 Medical Assistance Program $13.54M
93.600 Head Start/ Covid-19 Head Start $12.98M
93.658 Foster Care_title IV-E $11.10M
93.563 Child Support Enforcement $9.89M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $9.31M
14.218 Community Development Block Grants $8.23M
14.231 Emergency Solutions Grant Program $7.23M
93.914 Hiv Emergency Relief Project Grants $7.14M
20.205 Highway Planning and Construction $6.55M
21.027 Coronavirus State and Local Fiscal Recovery Funds $4.13M
14.239 Home Investment Partnerships Program $4.10M
93.659 Adoption Assistance $3.78M
93.667 Social Services Block Grant $3.68M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc)/ Covid-19- Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $2.73M
17.268 H-1b Job Training Grants $2.29M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $2.25M
97.106 Securing the Cities Program $2.24M
97.067 Homeland Security Grant Program $2.23M
14.267 Continuum of Care Program $1.96M
17.258 Wia Adult Program $1.77M
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.75M
14.218 Community Development Block Grants/entitlement Grants $1.72M
17.259 Wia Youth Activities $1.41M
93.569 Community Services Block Grant/ Covid-19- Community Services Block Grant $1.25M
97.044 Assistance to Firefighters Grant $1.07M
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $1.07M
20.200 Highway Research and Development Program $1.05M
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $949,501
17.207 Employment Service/wagner-Peyser Funded Activities $852,416
93.268 Covid-19 - Immunization Cooperative Agreements $743,210
16.922 Equitable Sharing Program $722,896
93.069 Public Health Emergency Preparedness $718,191
93.994 Maternal and Child Health Services Block Grant to the States $680,843
17.278 Wia Dislocated Worker Formula Grants $675,323
95.001 High Intensity Drug Trafficking Areas Program $604,180
16.575 Crime Victim Assistance $591,833
11.307 Economic Adjustment Assistance $553,992
16.741 Dna Backlog Reduction Program $544,713
93.645 Stephanie Tubbs Jones Child Welfare Services Program $531,202
45.024 Covid-19 - Promotion of the Arts Grants to Organizations and Individuals $500,000
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood/ Covid-19 - John H. Chafee Foster Care Program for Successful Transition to Adulthood $422,536
10.664 Cooperative Forestry Assistance $339,235
93.556 Marylee Allen Promoting Safe and Stable Families Program $338,161
16.738 Edward Byrne Memorial Justice Assistance Grant Program $308,460
10.551 Supplemental Nutrition Assistance Program (snap) $282,934
17.277 Covid-19 - Wioa National Dislocated Worker Grants $276,509
16.817 Byrne Criminal Justice Innovation Program $256,892
20.600 State and Community Highway Safety $255,614
93.090 Guardianship Assistance $251,889
10.558 Child and Adult Care Food Program (cacfp) $247,343
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $226,826
17.270 Reentry Employment Opportunities $201,650
93.136 Injury Prevention and Control Research and State and Community Based Programs $201,553
16.320 Services for Trafficking Victims $193,666
10.555 Covid-19- National School Lunch Program $176,196
16.576 Crime Victim Compensation $170,000
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $161,490
16.034 Covid-19- Coronavirus Emergency Supplemental Funding Program $155,747
14.241 Housing Opportunities for Persons with Aids $147,590
16.588 Violence Against Women Formula Grants $128,816
17.285 Apprenticeship USA Grants $124,128
17.245 Trade Adjustment Assistance $106,993
17.225 Unemployment Insurance $101,500
16.582 Crime Victim Assistance/discretionary Grants $99,261
97.042 Emergency Management Performance Grants $98,842
45.313 Laura Bush 21st Century Librarian Program $96,227
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $94,876
45.149 Promotion of the Humanities Division of Preservation and Access $71,079
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $60,646
16.825 Smart Prosecution Initiative $58,326
16.560 National Institute of Justice Research $58,152
93.568 Low-Income Home Energy Assistance $55,045
84.425 Covid-19 Education Stabilization Fund $54,180
21.017 Social Impact Partnerships to Pay for Results Act $52,775
93.317 Emerging Infections Programs $46,692
93.747 Covid-19 - Elder Abuse Prevention Interventions Program $46,566
16.036 Prosecuting Cold Cases Using Dna $45,993
16.609 Project Safe Neighborhoods $43,915
93.940 Hiv Prevention Activities Health Department Based $39,175
93.670 Child Abuse and Neglect Discretionary Activities $38,402
93.354 Covid-19 - Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $38,312
45.309 Museum Grants for African American History and Culture $37,320
97.047 Building Resilient Infrastructure and Communities (bric) $31,324
16.710 Public Safety Partnership and Community Policing Grants $26,091
20.507 Federal Transit Formula Grants $22,276
20.500 Federal Transit Capital Investment Grants $12,591
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $11,739
66.605 Performance Partnership Grants $8,026
17.801 Jobs for Veterans State Grants $7,644
66.808 Solid Waste Management Assistance Grants $3,800
93.648 Child Welfare Research Training Or Demonstration $2,991
15.605 Sport Fish Restoration $503
66.818 Brownfields Multipurtpose, Assessment. Revolving Loan Fund, and Cleanup Cooperative Agreements $211
84.196 Education for Homeless Children and Youth $77
21.019 Coronavirus Relief Fund $-3,763