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 24 CFR 578.73(a) The recipient must match all grant funds, except for leasing funds, with no less than 25 percent of funds or in kind contributions from other sources.
24 CFR 578.103(a)(11) The recipient must keep records of the source and use of contributions made to satisfy the match requirement in § 578.73. The records must indicate the grant and fiscal year for which each matching contribution is counted.
2 CFR 200.306(b) For all Federal grants, any matching funds must be accepted as part of the recipient’s match when such contributions meet all seven of the criteria listed in this regulation including being verifiable from the non Federal entity's records;
2 CFR 200.306(c) Unrecovered indirect costs, including indirect costs on match may be included as part of match only with the prior approval of HUD. Unrecovered indirect cost means the difference between the amount charged to the grant and the amount which could have been charged to the grant under the recipient’s approved negotiated indirect cost rate.
Condition The Commission was unable to provide adequate source documentation to support that the match requirement was met.
Questioned Costs $136,138
Identification of How Questioned Costs Were Computed Amount is the result of an unresolved finding from a monitoring visit from HUD.
Context In July 2023, HUD issued a finding related to amounts submitted for match requirements for grant MI0196L5F082013 in the total amount of $136,138. In addition, during audit testing of the match requirement, the Commission was unable to provide adequate source documentation to support that the match requirement was met for the grant agreements with period end dates during the audit period and for annual performance reports required. Due to the timing of HUD's report and the 2023 single audit, management was unable to adjust grant billings for grants whose grant period had already closed out. Cause and Effect Internal control policies were not in place to identify costs charged for matching that were not adequately documented. This lack of documentation results in noncompliance with the Uniform Guidance resulting in questioned costs of $136,138 at June 30, 2023.
Recommendation We recommend the Commission review its processes and controls to verify that all costs charged to the grant, including those costs charged to satisfy the match requirement, are adequately documented, consistent with the requirements of the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions Management agrees that match requirements for Continuum of Care awards have not been maintained as required by the Uniform Guidance. In July 2023, management was notified by HUD, after completion of an on site monitoring visit that the Commission's claimed matching expenses were not adequately supported by source documentation. In response, management has placed in service additional controls to ensure the compliance requirements are being monitoried and in place for the new program.