Finding 16164 (2022-001)

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Requirement
N
Questioned Costs
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Year
2022
Accepted
2023-03-30
Audit: 21392
Organization: The Homeless Alliance, Inc. (OK)

AI Summary

  • Core Issue: Records supporting housing quality inspections were not retained, violating federal retention requirements.
  • Impacted Requirements: Non-compliance with 2 CFR §200.334, which mandates a three-year retention period for relevant financial and supporting documents.
  • Recommended Follow-up: Update records retention policies to specify the required time period and conduct annual reviews to ensure ongoing compliance.

Finding Text

Finding ? 2022-001 ? Inadequate Records Retention Federal AL# 14.241 ? Housing Opportunities for Persons with AIDS Criteria: Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient (2 CFR ?200.334). Condition: Documentation supporting the Housing Quality Standards inspections to ensure housing met quality standards listed in 24 CFR ?574.310(b)(1)-(2) for the special tests and provisions compliance requirement for AL# 14.241 was missing. Cause and Effect: Policies and procedures regarding records retention is not in accordance with 2 CFR ?200.334 as it does not explicitly state a time period for records retention. As a result, events occurred during the year with no records retained as support. Recommendation: We recommend management update the written records retention policies and procedures to include a time period that is in accordance with 2 CFR ?200.334 and then communicate that policy to all employees to following during the daily course of operations. Additionally, we recommend an annual review of the policies and procedures to ensure continued compliance with 2 CFR ?200.334. Management?s Response: Homeless Alliance management agrees with the finding.

Corrective Action Plan

Finding ? 2022-001 ? Inadequate Records Retention Federal AL# 14.241 ? Housing Opportunities for Persons with AIDS Criteria: Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient (2 CFR ?200.334). Condition: Documentation supporting the Housing Quality Standards inspections to ensure housing met quality standards listed in 24 CFR ?574.310(b)(1)-(2) for the special tests and provisions compliance requirement for AL# 14.241 was missing. Cause and Effect: Policies and procedures regarding records retention is not in accordance with 2 CFR ?200.334 as it does not explicitly state a time period for records retention. As a result, events occurred during the year with no records retained as support. Recommendation: We recommend management update the written records retention policies and procedures to include a time period that is in accordance with 2 CFR ?200.334 and then communicate that policy to all employees to following during the daily course of operations. Additionally, we recommend an annual review of the policies and procedures to ensure continued compliance with 2 CFR ?200.334. Management?s Response: Homeless Alliance management agrees with the finding. Finding 2022-00 1 Response and Corrective Action In conjunction with our FY22 annual audit, please see the agency's corrective action plan below: Condition: Documentation supporting the Housing Quality Standards inspections to ensure housing met quality standards listed in 24 CFR ?574.3 10(b)(1)-(2) for the special tests and provisions compliance requirement for AL# 14.241 was missing. Corrective action: The agency has hired a full time compliance specialist for the program in which the finding occurred. The compliance specialist will be responsible for ensuring that all required documentation is retained appropriately. Moreover, agency management will update our written records retention policy to include a time period that is in accordance with 2 CFR 200.334 and communicate that policy to all employees. An annual management review of the agency's records retention policy will also be implemented. Expected completion date: June 30, 2023 Party Responsible: Haley Phelps Contact information: 405-415-8410 hphelps@homelessalliance.org

Categories

Subrecipient Monitoring Special Tests & Provisions Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.231 Emergency Solutions Grant Program $1.62M
14.267 Continuum of Care Program $940,575
14.241 Housing Opportunities for Persons with Aids $939,509
14.239 Home Investment Partnerships Program $670,000
21.023 Emergency Rental Assistance Program $621,719
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $336,429
14.218 Community Development Block Grants/entitlement Grants $149,412
14.261 Homeless Management Information Systems Technical Assistance $126,766
97.024 Emergency Food and Shelter National Board Program $56,163