HOUSING FORWARDNon-Profit

Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Continuum of Care, CFDA # 14.267 2022-001: Criteria: According to 2 CFR 200.430 i(i)(vii) charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and there should be support to the distributions of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: In gaining our understanding of controls over payroll, we noted the following control: the majority of the employees at Housing Forward and Subsidiary work for only one grant with the exception of management that may work for two. We viewed 40 timesheets related to the CoC program of which twelve showed the employee working for multiple grants but did not include the number of hours worked for each program on the timesheet, it was tracked through management and staff. Cause: The timesheets that were missing a breakdown of time and effort applied to each grant did not have a detailed tracking of hours by grants to remind employees to allocate their time by grant. The allocation was made based on a percentage rather than the actual time worked. Effect: The hours charged to a program could be under or overstated based budget compared to actual hours that should be documented on the timesheets. Auditor?s Recommendation: We recommend that the timesheets revised to either have ability to breakout the hours per day by grant and remind staff the importance to track their time by funder. Management Response: Employees have transitioned to submitting time and effort bi-weekly within the ADP payroll system to ensure timeliness of allocation of wages. Hours will be reported based on actual time worked in projects, even when employees are working in a single project. These hours are used to allocate salaries and wages and unpaid time off bi-weekly. Fringe benefits will be allocated on a monthly basis using the allocation of hours for that month. Allocation of hours and coding is reviewed by the Finance department for accuracy and allowance before submittal of payroll. If changes are needed after processing, Finance staff will work with staff to correct time and effort reporting through a manual time and effort report.

GSA_MIGRATION