Finding 573162 (2024-001)

-
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-08-08
Audit: 363980
Organization: Kentucky Housing Corporation (TN)
Auditor: Crowe LLP

AI Summary

  • Core Issue: Unallowable costs totaling $242,398 were incurred due to payments made to fictitious vendors by a subrecipient.
  • Impacted Requirements: Lack of internal controls and timely monitoring led to violations of 2 CFR Part 200, resulting in questioned costs across federal programs.
  • Recommended Follow-Up: Enhance internal controls and establish regular monitoring procedures for subrecipients to prevent future occurrences of unallowable costs.

Finding Text

Finding 2024-001 – Unallowable Subrecipient Costs (Deficiency) Information on the Federal Programs: Continuum of Care – AL # 14.267 and Emergency Solutions Grant Program – AL # 14.231. Criteria: According to 2 CFR Part 200, Subpart F, 200.516, “the auditor must report the following as audit findings in a schedule of findings and questioned costs… Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards.” Condition: During the current fiscal year the Corporation, based on monitoring procedures performed, determined that one of their subrecipients had been making payments to fictitious vendors and/or vendors with a significant conflict of interest resulting in resulting in questioned or unallowable costs from fiscal year 2023 and fiscal year 2024 across the federal programs listed above. Cause: There was an apparent lack of internal controls and/or segregation of duties within the subrecipient entity that did not prevent these unallowable costs from being incurred at the subrecipient level. Additionally, Corporation management did not perform subrecipient monitoring procedures in a timely manner which resulted in unallowed costs being incurred before ultimately being detected by the Corporation. Effect: Questioned or unallowable known costs of $242,398 (as identified by the Corporation) from fiscal year 2023 and fiscal year 2024 were incurred across the federal programs listed below. Questioned Costs: Federal Program FY2024 Amount FY2023 Amount AL # 14.231 $24,753 $54,737 AL # 14.231 – COVID $0 $46,176 AL # 14.267 $37,602 $2,928 Unknown $6,813 $69,389 Context: As part of subrecipient monitoring, the Corporation identified some questioned costs related to one specific subrecipient. Management of the Corporation performed testing of the disbursements made to the subrecipient while the Executive Director was employed there (from July 31, 2022 through January 4, 2024) and determined that there were $242,398 of disbursements that were either unallowable based on the supporting documentation, or were questioned costs due to lack of supporting documentation. Crowe tested a sample of the disbursements from the same time period and the results from that sample agreed to the results the Corporation found.

Corrective Action Plan

The Corporation identified a subrecipient’s misuse of grant funds during a regular audit of draws and a scheduled monitoring review/technical assistance consultation for the agency. Ethic complaints were received by the Corporation during the same timeframe regarding the subrecipient’s management which expanded the scope of the financial review. As a result of these monitoring efforts, the Corporation identified ineligible and questioned costs, and efforts are underway to recapture ineligible and unsupported costs. The Corporation has put the following policies and procedures in place to mitigate future risk: 1. Biennial Risk Assessment with Annual Updates 2. Annual Project Compliance Report (APCR) required by subrecipient agencies (with the exception of subrecipients receiving only Department of Energy and LIHEAP grants for the Weatherization Assistance Program, which are governed by separate monitoring procedures). 3. Enhanced Draw Monitoring and draw documentation requirements 4. Expansion of the Corporation’s Compliance and Training Team Given the policies, procedures, and changes outlined above, the Corporation feels confident it will be able to comply with its Compliance Monitoring Plan going forward and identify any concerns with subrecipient compliance in a timely manner. Curtis Stauffer, Managing Director, Housing Contract Administration, and applicable compliance staff will implement by October 1, 2024.

Categories

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.117 Mortgage Insurance Homes $509.24M
14.871 Section 8 Housing Choice Vouchers $31.09M
64.114 Veterans Housing Guaranteed and Insured Loans $26.19M
10.410 Very Low to Moderate Income Housing Loans and Loan Guarantees $21.62M
21.026 Covid-19 - Homeowner Assistance Fund $17.21M
14.239 Home Investment Partnerships Program $12.36M
21.023 Covid-19 - Emergency Rental Assistance Program $12.17M
81.042 Weatherization Assistance for Low-Income Persons $9.48M
14.267 Continuum of Care Program $7.05M
93.568 Low-Income Home Energy Assistance $6.50M
14.879 Mainstream Vouchers $3.72M
14.U01 Emergency Housing Voucher $2.11M
14.231 Emergency Solutions Grant Program $1.14M
14.275 Housing Trust Fund $1.09M
14.241 Housing Opportunities for Persons with Aids $982,735
14.327 Performance Based Contract Administrator Program $678,520
14.239 Covid-19 - Home Investment Partnerships Program $336,567
14.896 Family Self-Sufficiency Program $165,857
14.856 Lower Income Housing Assistance Program Section 8 Moderate Rehabilitation $82,164