Finding 30877 (2022-005)

Material Weakness
Requirement
BGL
Questioned Costs
-
Year
2022
Accepted
2023-06-20

AI Summary

  • Core Issue: The Alliance lacks specific controls in their procedures for managing grant activities, leading to a material weakness in compliance with grant provisions.
  • Impacted Requirements: Key areas needing improvement include grant management oversight, reporting accuracy, financial reconciliation, and eligibility verification for recipients.
  • Recommended Follow-Up: Enhance written procedures to include designated responsibilities, regular reviews, and a clear timeline for financial reporting and compliance checks.

Finding Text

2022-5 Emergency Solutions Grant Program ? Assistance Listing No. 14.231, Grant No. APZ11, Grant Period ? Year Ended June 30, 2022, Covid Grants Material Weakness: Although the Alliance had written procedures for receipt, disbursement, and accounting for grant monies, the procedures do not address specific controls that are needed to provide assurance that grant activities are conducted in accordance with grant provisions. Written procedures should be implemented and/or enhanced to address the grant functions, including: ? Designation of an employee to be responsible for grant management and oversight. ? Grant reporting, including appropriate review and approval. ? Reconciling grant financial reports with supporting accounting records and review and approval by a responsible official before filing. ? A documented time schedule for filing financial reports with grantors and polices for identifying special requirements of grants. ? Recording charges of direct and indirect costs of grants. ? Reviewing charges to grants, including documentation that the expense is allowable to the grant. ? Reviewing and approving that recipients are eligible under program requirements. ? Employee time allocation method to ensure compliance with Uniform Guidance.

Corrective Action Plan

Views of Responsible Official: Current management indicated that the former Executive Director of HHA, former Finance Director of HHA, and a former employee were employed by HHA, and the former Executive Director and Finance Director controlled all aspects of HHA?s management and finances during the relevant audited period. The former Executive Director?s employment with HHA was terminated on October 10, 2022. The former Finance Director?s employment with HHA was terminated on October 20, 2022. The third employee?s employment with HHA was terminated on October 11, 2022. Additionally, all but two of the Board of Directors who served during the period in which the irregularities occurred have been replaced. HHA appointed the current Executive Director, Crystal Harrison (?Executive Director?), on October 10, 2022, as Interim Executive Director and promoted her to the position of Executive Director on October 26, 2022. The current Executive Director has diligently searched for all documents and records for all purchases, expenses, and cash distributions at issue during the former Executive Director?s tenure as Executive Director. However, no such documents or records were located on site at HHA?s offices or on HHA?s computers or devices. In early April 2023, HHA?s attorney served the former Executive Director, former Finance Director, and former employee with a demand to produce the missing documents and records but each responded that they had no such documents or records in their possession. Unfortunately, because of the actions of the former Executive Director, Finance Director, and employee, HHA lacks sufficient operating funds to pursue a civil suit to recover the losses caused by these former employees. Further, HHA?s errors and omissions insurance policy only covers third-party claims. As such, HHA has directed its attorney to take all appropriate action to pursue criminal charges of grand theft/embezzlement and fraud against these former employees upon completion of the audit. HHA?s attorney has already reached out to law enforcement to begin this process. Once the formal criminal complaint is filed, law enforcement will be empowered to subpoena the missing documents and records (should said documents and records still exist) from the former employees, as well as their banking and financial records (including tax returns) to track the suspicious expenses and cash distributions at issue. The current Executive Director, with the full support of HHA?s Board, is committed to taking all action necessary to ensure compliance with the rules and procedures already in place regarding expenses and cash distributions, as well as to enact new enhanced procedures for periodic reviews of these procedures to timely detect deficiencies and ensure compliance going forward. In addition, the current Executive Director will implement a process to ensure that backup records are maintained electronically as well as in a paper form.

Categories

Allowable Costs / Cost Principles Material Weakness Reporting Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.231 Emergency Solutions Grant Program $3.04M
14.267 Continuum of Care Program $330,170
93.558 Temporary Assistance for Needy Families $36,860
14.218 Community Development Block Grants/entitlement Grants $8,304