Finding 30881 (2022-009)

-
Requirement
G
Questioned Costs
$1
Year
2022
Accepted
2023-06-20

AI Summary

  • Core Issue: Matching expenses for the Emergency Solutions Grant did not meet documentation requirements, risking disallowance of costs.
  • Impacted Requirements: Federal funds under ESG Program require 100% matching, but only 6 out of 14 tested items were compliant.
  • Recommended Follow-Up: Establish written procedures for supervisory approval of matching costs to ensure proper documentation and compliance.

Finding Text

2022-9 Emergency Solutions Grant Program ? Assistance Listing No. 14.231, Grant No. APZ11, Grant Period ? Year Ended June 30, 2022, Covid Grants Condition: Matching expenses did not meet the documentation requirements to be an allowable matching cost. Criteria: Federal funds provided under the ESG Program, CFDA 14.231 must be matched 100%. Cause: The Alliance did not have written procedures to determine that matching costs were adequately documented, including record retention requirements. Effect: The cost of assistance may be disallowed. Context: Although HHA incurred expenses to match 100% of Federal funds, of the 14 test items eligible for matching, six met the requirements for matching. The remaining eight test items (totaling $11,264.36 from direct services and $1,686.70 from general expenses) did not meet the documentation requirements in all instances to determine the activities allowed or unallowed or allowable cost. Recommendation: Procedures should be implemented for supervisory approval of matching costs to provide assurance that matching costs are adequately documented. TOTAL QUESTIONED COSTS FOR EMERGENCY SOLUTIONS GRANT PROGRAM ? Assistance Listing No. 14.231, Grant No. APZ11 - $11,264.36

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

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

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