Finding Text
Assistance Listing, Federal Agency, and Program Name 14.267, U.S. Department of Housing and Urban Development Continuum of Care Program
Federal Award Identification Number and Year N/A
Pass through Entity N/A
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding No
Criteria The Commission should have written policies in place that comply with appropriate grant regulations (24 CFR 576.500(b), 24 CFR 578.103(c), 24 CFR 578.103(d), 24 CFR 578.91(b)(4), 24 CFR 578.75(g)(1 & 2), 24 CFR 578.103(a)(13)). The Commission is also required to retain their grant agreements in accordance with 2 CFR 200.334.
Condition The Commission did not have required written policies in place during the year under audit nor could copies of grant agreements be provided for when the Commission became the direct recipient of the grant awards.
Questioned Costs N/A
Identification of How Questioned Costs Were Computed N/A
Context During the year ended June 30, 2023, the Commission became the direct recipient of the Continuum of Care awards from the City of Lansing, Michigan. In July 2023, HUD performed an on site monitoring review of the program and issued several findings related to lack of required written policies.
Cause and Effect The City of Lansing was the direct recipient of the Continuum of Care grant and the Commission was the subrecipient until September 2022. No policies, procedures, training, or technical assistance was provided by the City when the Commission became the direct recipient. Management was unaware of all the program requirements. As a result, the Commission violated several regulations and could potentially violate others due to a lack of understanding of program policies and procedures to ensure program compliance. Additionally, the Commission was unable to provide all of the grant agreements from the City.
Recommendation We recommend the Commission review all grant regulations to ensure all required written policies have been adopted and that all appropriate agreements are in place and accessible. Additionally, the Commission should work with the City and HUD to obtain all the grant agreements from the date of transition. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding as reported. To correct this finding, the Commission reviewed its policies and procedures and revised them as needed to comply with federal regulations. The policies were presented and approved at the August 2023 board meeting. The Commission has sent the revised policies to HUD for its review and approval.