Finding 564239 (2024-002)

Significant Deficiency
Requirement
G
Questioned Costs
-
Year
2024
Accepted
2025-06-09
Audit: 358335
Organization: Housing Connector (WA)
Auditor: Clark Nuber Ps

AI Summary

  • Core Issue: There is a significant deficiency in internal controls for tracking compliance with matching fund requirements for federal awards.
  • Impacted Requirements: The Organization is not following 2 CFR section 200.306, which mandates proper documentation and tracking of matching contributions.
  • Recommended Follow-Up: Management should enhance internal controls by implementing a tracking system for matching funds and maintaining detailed records to ensure compliance.

Finding Text

Significant deficiency in internal control over compliance related to matching compliance requirements. Federal Agency: US Department of Treasury Pass-Through Entity: State of Colorado Department of Local Affairs - Division of Housing Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number: H4HRG23147 Criteria Nonfederal entities must follow the standards for documentation of personnel expenses set out at 2 CFR section 200.306(a). Under this guidance, the entity that accepts any cost share funds (including cash and third-party in-kind contributions, and also including funds committed by the recipient, subrecipient, or third parties) as part of the recipient's or subrecipient's contributions to a program when the funds among others: 1) are verifiable in the recipient's or subrecipient’s records. Section III - Reportable Findings and Questioned Costs for Federal Awards Condition/Context/Cause The Organization entered into an agreement with match requirements to qualify for a federal match. The agreement stipulates the Organization has until September 2026 to expend the necessary matching funds. During our testing of matching for this award we noted that the Organization did not have controls in place to track and monitor compliance with the matching requirement. Effect The effect is that the Organization was not tracking spending to date that qualifies to meet the matching requirement for this award in compliance with the requirements of 2 CFR section 200.306. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendation We recommend management update its internal control process for a tracking system of matching funds to ensure compliance with 2 CFR 200.306 is met. This includes maintaining detailed records and documentation of all matching contributions. Views of Responsible Official and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Corrective Action Plan

Corrective action planned: Housing Connector will develop and implement a written policy to address company match contributions used to meet federal cost share requirements, in alignment with 2 CFR 200.306. The policy will provide general guidance on the allowability, tracking, and reporting of match to ensure compliance with federal grant regulations. Relevant staff will be informed once the policy is finalized.

Categories

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Other Findings in this Audit

  • 564238 2024-001
    Significant Deficiency
  • 1140680 2024-001
    Significant Deficiency
  • 1140681 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.46M
14.218 Community Development Block Grants/entitlement Grants $54,867
14.239 Home Investment Partnerships Program $26,493