Finding Text
Finding 2023-002 Significant Deficiency: Matching, Earmarking, and Level of Effort – Control Finding
ALN 14.267 – Continuum of Care
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: City of St. Louis Department of Human Services
Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program.
Condition: We noted through procedures performed that management did not perform a complete review of match information to ensure its accuracy, prior to it being submitted to the pass-through entity.
Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of expenditures required to be matched by the Archdiocese was performed and that proof of such reviews was documented and retained.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting.
Questioned Costs: Not applicable.
Context: Six out of 40 match expenditures sampled, related to in-kind work hours, did not have a proof of review documented and retained prior to submission to the pass-through entity.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend that management assign the review of these types of expenditures to an individual that is directly supervising the volunteers. In addition, a schedule should be created to document the in-kind hours worked by each volunteer to retain as support for the expenditures.
Views of Responsible Officials: St. Patrick Center (SPC) will develop a control procedure to put in place to have In-Kind work hours reviewed by supervisor of volunteers. The supervisor will have volunteers sign-off on their volunteer hours worked. The volunteer sign-off sheets will be reviewed and a report tabulating monthly total hours will be developed. The volunteer supervisor will sign-off on the report, and the volunteer’s supervisor, after their review, prior to forwarding to finance. SPC will retain sign-off reports for reference as needed for audit purposes. Finance will review calculation of match total when processing monthly invoice