Finding Text
Significant Deficiency 2022-001 Federal Agency: Department of Housing and Urban Development Pass-Through Entity: Office of Temporary & Disability Assistance Assistance Listing Numbers: 14.231 Emergency Services Program Pass-through Grant Numbers: C00681GG Program Name: Emergency Solutions Grants Program Criteria: 24 CFR section 576.203 requires that the recipient pay each subrecipient for allowable costs within thirty days after receiving the subrecipient?s complete payment request. Condition: During our testing, we noted three of the payments selected for testing and made to Unity House?s subrecipients, were made more than thirty days after Unity House received all of the supporting documentation from their subrecipients. The payments were made 7, 14, and 6 days past the thirty day mark. Cause: Unity House?s practice is to make payments as the invoices are received; however on these occasions? payments were made late. Effect: The subrecipients are delayed in receiving the funds reimbursing them for their expenditures. Questioned Costs: None Context/Sampling: We selected nine payments made to subrecipients, noting that three of them were paid out later than thirty days after final invoices were received from their subrecipients. Repeat Finding: No Recommendation: Unity House should develop a tracking system for when final supporting documentation is received for each subrecipient claim to ensure that all claims are paid prior to the thirty days limit. There should also be sufficient documentation kept to support dates of final receipt. View of Responsible Officials and Corrective Action Plan: Management is in agreement with the finding noted above. Given the finding above, we have developed the following, comprehensive Corrective Action Plan to decrease the likelihood of any future findings, similar to those found above. Prior to the findings noted in this audit, Unity House procured a comprehensive grants management software package. One of the intents of this software is to streamline the processes related to payments associated with every grant Unity House holds. In July 2023, procedures for tracking and processing subrecipient payments were updated. Dates related to internal approvals, receipt of final invoices, and payments issued to subrecipients will be tracked in our grants management system (anticipated to go live in August 2023). Quarterly reports will be generated in the system to monitor compliance. Additionally, a Subrecipient Check Request Form, which prompts a check to be cut by Unity House within two business days, has been created and will be submitted by the Unity House Subaward Manager upon receipt of final invoices. The responsible party is Stacey Faulisi, CFO and this is expected to be fully implemented by October 1, 2023, with November 1, 2023 being the first quarterly fidelity review.