Finding Text
Assistance Listing Program Title and Number: Continuum of Care Program 14.267
Criteria
2 CFR § 200.308, 200.309 and 200.403(h)) 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
During period of performance testing for the Continuum of Care Program two instances were identified
where expenses were incurred outside of the allowable timeframe. The sample size was extended to
address this deficiency, and no additional exceptions were noted.
Cause
This noncompliance may have resulted from inadequate controls to validate expense dates during
approval and/or lack of staff training on period-of-performance requirements
Effect
There is an increased audit risk for federal fund misuse and a potential for unallowable expense
reimbursement repayment.
Recommendation
1. Implement pre-approval controls: Require date validation for all expenses against the award’s
period of performance.
2. Conduct training: Educate staff on 2 CFR requirements and period-of-performance limitations.
3. Perform periodic reviews: Monitor compliance quarterly to detect outliers.
Management’s Response
Management agrees with this finding, see the Corrective Action Plan.