Finding 31600 (2022-001)

Significant Deficiency
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2023-03-28

AI Summary

  • Core Issue: Unallowable costs were charged by subrecipients for the Emergency Solutions Grant Program, leading to noncompliance with federal regulations.
  • Impacted Requirements: The organization failed to maintain effective internal controls as required by 2 CFR 200.303, resulting in disallowed costs and reimbursement requests.
  • Recommended Follow-Up: Consistently apply control procedures to monitor subrecipients' compliance and ensure only allowable costs are submitted for reimbursement.

Finding Text

Finding 2022-001: Unallowable costs charged by subrecipients and submitted for reimbursement Department of Housing and Urban Development Emergency Solutions Grants Program ? Federal Assistance Listing #14.231 Passed through Florida Department of Children and Families Contract No. CP005 Grant period: Year ended June 30, 2022 Criteria: In accordance with 2 CFR 200.303, non-Federal entities must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Condition: Emergency Solutions Grant Program funds were paid to two sub-recipients, during the year ended June 30, 2022, which were subsequently determined to be unallowable costs as a result of the sub-recipients? noncompliance with the grant contract. Cause: Control procedures in place related to monitoring of sub-recipients? compliance with the grant contract were not consistently applied in order to prevent disallowed costs paid to sub-recipients and submitted for reimbursement from the pass-through granting agency. Effect: Noncompliance with allowable costs/cost principles required under the Federal grant award. Certain costs charged to the grant have been disallowed and certain costs have been requested to be paid back to the pass-through granting agency. Questioned Costs: Undeterminable. Context: During the audit, the auditors were notified by the Organization?s management that $120,000 of Emergency Solutions Grant Program funds were paid to one sub-recipient, during the year ended June 30, 2022, and were later notified by the pass-through granting agency that the sub-recipient did not submit required documentation for the costs incurred. Therefore, $60,000 already reimbursed by the grant, has been requested to be paid back, and another $60,000 submitted for reimbursement, was not reimbursed by the grant. The Organization is continuing to work with the agency and the sub-recipient to rectify the noncompliance, which could result in the costs being allowed. In addition, there was $245,172 paid to another sub-recipient, during the year ended June 30, 2022, of which the Organization discovered during regular monitoring of the sub-recipient that the sub-recipient was not in compliance with their agreement. Therefore, the Organization terminated the agreement with the sub-recipient and requested the funds be returned. The Organization returned the funds back to the pass-through granting agency in the next fiscal year. Recommendation: The Organization should apply control procedures in place consistently over monitoring of sub-recipients? compliance and over all costs incurred by sub-recipients to ensure that only allowable costs for grants are submitted for reimbursement. Management?s Response: Management agrees with the finding. See ?Corrective Action Plan? section.

Corrective Action Plan

RE: Finding 2022-001: Unallowable costs charged by subrecipients and submitted for reimbursement In addition to required annual monitoring of subrecipients, United Way of North Central Florida will implement the following Corrective Action Plan to address finding 2022-001. ?Institute mandatory ESG Admin training for all ESG funded providersregardless of their funding history under the program. ?Conduct monthly case file pulls at random for all providers across all programs. Completion date is ongoing throughout the current fiscal year Amber Miller, President & CEO, will serve as the primary contact for this Corrective Action Plan.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 608042 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.231 Covid-19-Emergency Solutions Grant Program $3.28M
14.267 Continuum of Care Program $87,361
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $51,120
14.231 Emergency Solutions Grant Program $27,179