EIN: 311222236
UEI: VG6JK25MNMC7
Audit also covers 4 related EINs: 311324717, 311361020, 311374460, 383241909
Audited by: EisnerAmper LLP
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 7, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 7, 2027 (128 days from today).
What is a management decision? →FAC accepted this audit on August 22, 2025 — management decision was due February 22, 2026.
FAC accepted this audit on April 17, 2024 — management decision was due October 17, 2024.
FAC accepted this audit on April 17, 2024 — management decision was due October 17, 2024.
FAC accepted this audit on April 17, 2024 — management decision was due October 17, 2024.
FAC accepted this audit on April 17, 2024 — management decision was due October 17, 2024.
FAC accepted this audit on April 17, 2024 — management decision was due October 17, 2024.
FAC accepted this audit on April 17, 2024 — management decision was due October 17, 2024.
FAC accepted this audit on April 17, 2024 — management decision was due October 17, 2024.
FAC accepted this audit on April 23, 2024 — management decision was due October 23, 2024.
FAC accepted this audit on January 21, 2025 — management decision was due July 21, 2025.
FAC accepted this audit on February 24, 2024 — management decision was due August 24, 2024.
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
FAC accepted this audit on September 30, 2021 — management decision was due March 30, 2022.
FAC accepted this audit on September 29, 2020 — management decision was due March 29, 2021.
CFDA Number, Federal Agency, and Program Name 14.267, U.S. Department of Housing and Urban Development, Continuum of Care Federal Award Identification Number and Year CHN 20 CoC, fiscal year 2019 Pass through Entity Community Shelter Board Finding Type Significant deficiency and material noncompliance with laws and regulations Repeat Finding ? No Criteria Appendix IV to 2 CFR 200 Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit Organizations indicates that the distribution base may be total direct costs (excluding capital expenditures and other distorting items, such as subawards for $25,000 or more), direct salaries and wages, or other base which results in an equitable distribution. Condition CHN charged the federally approved indirect cost rate on the first $25,000 of contracts with subcontractors. The Community Shelter Board submitted a question to HUD in order to determine if this was allowable in February of 2018, and received a response in June of 2020 indicating this was not allowable. This resulted in CHN receiving reimbursement for unallowable costs totaling $81,930 for fiscal year 2019. Questioned Costs $81,930. Identification of How Questioned Costs Were Computed Questioned costs were computed by taking the first $25,000 of each contract with a subcontractor, multiplied by the approved indirect cost rate of 17.64 percent. Context The indirect cost rate was applied to contracts with subcontractors, which is not allowed per the requirements included in the criteria above. This resulted in CHN requesting and receiving payment of unallowable costs totaling $81,930 for the grant period from July 1, 2019 through December 31, 2019. Cause and Effect CHN charged the federally approved indirect cost rate on the first $25,000 of contracts with subcontractors, which is not allowable under Appendix IV to 2 CFR 200 Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit Organizations. This resulted in $81,930 of unallowable costs. The SEFA was reduced by the amount of questioned costs at December 31, 2019. Recommendation We recommend that CHN follow the guidance provided in the email communication from CSB dated June 2, 2020, including repayment of the questioned costs. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding and recommendation, as reported, and has ceased charging the indirect cost rate to contracts with subcontractors and updated its policies. Additionally, management has repaid the full amount of unallowable costs to the Community Shelter Board on July 30, 2020.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name 14.267, U.S. Department of Housing and Urban Development, Continuum of Care Federal Award Identification Number and Year CHN 20 CoC, fiscal year 2019 Pass through Entity Community Shelter Board Finding Type Significant deficiency and material noncompliance with laws and regulations Repeat Finding ? No Criteria Appendix IV to 2 CFR 200 Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit Organizations indicates that the distribution base may be total direct costs (excluding capital expenditures and other distorting items, such as subawards for $25,000 or more), direct salaries and wages, or other base which results in an equitable distribution. Condition CHN charged the federally approved indirect cost rate on the first $25,000 of contracts with subcontractors. The Community Shelter Board submitted a question to HUD in order to determine if this was allowable in February of 2018, and received a response in June of 2020 indicating this was not allowable. This resulted in CHN receiving reimbursement for unallowable costs totaling $81,930 for fiscal year 2019. Questioned Costs $81,930. Identification of How Questioned Costs Were Computed Questioned costs were computed by taking the first $25,000 of each contract with a subcontractor, multiplied by the approved indirect cost rate of 17.64 percent. Context The indirect cost rate was applied to contracts with subcontractors, which is not allowed per the requirements included in the criteria above. This resulted in CHN requesting and receiving payment of unallowable costs totaling $81,930 for the grant period from July 1, 2019 through December 31, 2019. Cause and Effect CHN charged the federally approved indirect cost rate on the first $25,000 of contracts with subcontractors, which is not allowable under Appendix IV to 2 CFR 200 Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit Organizations. This resulted in $81,930 of unallowable costs. The SEFA was reduced by the amount of questioned costs at December 31, 2019. Recommendation We recommend that CHN follow the guidance provided in the email communication from CSB dated June 2, 2020, including repayment of the questioned costs. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding and recommendation, as reported, and has ceased charging the indirect cost rate to contracts with subcontractors and updated its policies. Additionally, management has repaid the full amount of unallowable costs to the Community Shelter Board on July 30, 2020.
Finding Number: 2019-001 Condition: In 2018, the local HUD office questioned the Community Shelter Board about whether regulations permitted the indirect cost rate to be applied to costs from contracts with subcontractors. Because CSB couldn?t find any formal written guidance on the issue, the local HUD office through CSB asked CHN to ask its cognizant agency for a formal determination. CSB also submitted the question to the national HUD office for a determination. CHN?s cognizant agency informed CHN the costs could be included, but HUD had discretion to determine otherwise. On June 1 2020, HUD answered CSB that HUD had determined the indirect cost rate could not be applied to costs from contracts with subcontractors. This resulted in CHN receiving reimbursement for unallowable costs totaling $81,930 for fiscal year 2019. Planned Corrective Action: After confirming with its legal counsel that HUD had reasonably interpreted the regulation, management agrees with the finding and recommendation, as reported, and has ceased charging the indirect cost rate to contracts with subcontractors.. Additionally, management has repaid the full amount of unallowable costs to the Community Shelter Board on July 30, 2020. Contact person responsible for corrective action: Christina Alutto, CAFO Anticipated Completion Date: July 30, 2020
FAC accepted this audit on July 18, 2019 — management decision was due January 18, 2020.
FAC accepted this audit on September 5, 2018 — management decision was due March 5, 2019.
FAC accepted this audit on June 6, 2017 — management decision was due December 6, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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