Finding 478407 (2022-003)

Program Name – Continuum of Care Assistance Listing Number – 14.267 Pass-through Entity – N/A Finding Type – Material Weakness and Noncompliance Criteria – A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Condition and Description – For 3 grants the Organization drew funds prior to the period of performance. Questioned Costs – $37,062. Identification of a Repeat Finding – This is a repeat finding and was identified as Finding 2021-005 in the prior year single audit. Cause/Effect The Organization drew funds prior to the operating start date of the grant. The draws were outside of the period of performance and are to be returned to the US Department of Housing and Urban Development. Recommendation – The Organization should ensure that grant funds are not drawn until after the operating start date of the grant. View of Responsible Official and Corrective Action Plan – We agree with the auditors' comments, and the following action will be taken to improve the situation. Following the completion of the 2021 Single Audit, we adjusted the Organization’s Accounting Policies & Procedure Manual to include detailed information outlined in HUD's electronic Line of Credit Control System (eLOCCS) inclusive of the roles and responsibilities of the system's Users and Approving Official. Specifically, Accounting Department Leadership (i.e., the Chief Financial Officer), designated accounting personnel (i.e., Accountants), and/or agency Executive Leadership (i.e., CEO/Executive Director), must be cognizant of a grant's period of performance.