EIN: 410828779
UEI: K1M4EX8HBDZ8
Audited by: CliftonLarsonAllen LLP
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 30, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 3, 2025. 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 March 3, 2026 (180 days ago).
What is a management decision? →The Organization did not have evidence that a rental records review was performed to for an individual to ensure the contract rent being paid was comparable with those paid for unassisted units and that the portion of rents paid with grant funds do not exceed fair market values. Questioned costs: None Context: During our testing, we identified one out of twenty four persons tested, where the Organization did not have documented review of rental records to ensure the contract rent being paid was comparable with those paid for unassisted units and that the portion of rents paid with grant funds do not exceed fair market values. Cause: The Organization did not document that a rental records review was performed. Effect: The Organization is not in compliance with the federal requirement of checking rent reasonableness before admitting a participant. Repeat Finding: No Recommendation: We recommend the Organization evaluate its procedures and implement an additional control to document rental rate checks are occurring prior to entering into rental contract. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number and Year: Multiple Pass-Through Agency: Hearth Connection Pass-Through Number(s): Multiple Award Period: January 1, 2024 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 578.49(b)(2) requires that when grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents. Condition: The Organization did not have evidence that a rental records review was performed to for an individual to ensure the contract rent being paid was comparable with those paid for unassisted units and that the portion of rents paid with grant funds do not exceed fair market values. Questioned costs: None Context: During our testing, we identified one out of twenty four persons tested, where the Organization did not have documented review of rental records to ensure the contract rent being paid was comparable with those paid for unassisted units and that the portion of rents paid with grant funds do not exceed fair market values. Cause: The Organization did not document that a rental records review was performed. Effect: The Organization is not in compliance with the federal requirement of checking rent reasonableness before admitting a participant. Repeat Finding: No Recommendation: We recommend the Organization evaluate its procedures and implement an additional control to document rental rate checks are occurring prior to entering into rental contract. Views of responsible officials: There is no disagreement with the audit finding.
Continuum of Care Program – Assistance Listing No. 14.267 Recommendation: We recommend the Organization evaluate its procedures and implement an additional control to document rental rate checks are occurring prior to entering into rental contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In March 2024, Avivo created a Rental Assistance Administrator (RAA) role to oversee all rental administration processes for our subsidy housing programs, including paperwork and compliance. The role developed over 2024 and was reviewed and reclassified from purely administrative to leadership and compliance in March 2025, after a year of development. With the new role, we have shifted responsibility off managers for final approval of documentation and have them focusing solely on programming and service provision. The RAA has created standardization across programs, ensures high levels of compliance, ensures no payments are sent without full, accurate documentation and helps to identify common errors early on and areas for training or support. To ensure the most accurate and complete paperwork is uploaded to our electronic health record, we are now submitting all subsidy paperwork through the electronic health system for review and approval. This solidified our process and eliminated managers creating their own processes. Switching to all approvals being electronic ensures that the most accurate and complete paperwork is available and in one place. RAA also approves and processes all rental payments from the service side and if paperwork is not approved, no payments will be released. Program Leadership, RAA and Director of Housing Operations meet bimonthly to review the program manual and policies overall to ensure most accurate policies and practices are reflected. We also updated our checklist cover sheets for all subsidy paperwork changes to reflect the changes from paper to electronic health record and have made several pieces of the subsidy paperwork process available to be completed electronically. In regards to rent reasonableness specifically, Program Leadership, RAA and Director of Housing Operations are planning two work sessions in late August and September, to review policies, current paperwork requirements and to plan additional training and supports for frontline staff to ensure full understanding of rent reasonableness and overall best practices. As part of this, we will review current paperwork and see if there are improvements that could be made, including making documentation fully electronic. We will also be looking at timelines around paperwork submission and sending out payments. Once it is determined what actions are the best solutions, managers will present changes and retrain on rent reasonableness and any other compliance improvements in team meetings in October 2025. Name(s) of the contact person(s) responsible for corrective action: Courtney Knoll, Program Director Planned completion date for corrective action plan: October 2025
During our testing, we identified 2 expenses charged to the next grant period, instead of the correct period of the grant. Questioned costs: $16.44 Context: During our testing, we identified 2 expenses that were inadvertently entered into the wrong accounting period due to a system issue which caused the expenses to be billed to the wrong grant period. Cause: The Organization’s system encountered an issue with the sync tool that is used to integrate mileage data from the organization’s payroll system. Effect: The Organization was not in compliance with the period of performance requirement since costs were charged to the grant prior to the start of the period of performance. Repeat Finding: No Recommendation: We recommend the Organization evaluate its procedures and implement an additional control to ensure costs are charged to the grant during the period of performance. Views of responsible officials: There is no disagreement with the audit finding. This was an exception and controls have been put in place to ensure that this does not re-occur.
Show full finding ▾Hide full finding ▴2024 – 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number and Year: Multiple Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: January 1, 2024 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (45 CFR 75.309(a)) notes a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in § 75.461) and any costs incurred before the HHS awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Funds available to pay allowable costs during the period of performance include both Federal funds awarded and carryover balances. Condition: During our testing, we identified 2 expenses charged to the next grant period, instead of the correct period of the grant. Questioned costs: $16.44 Context: During our testing, we identified 2 expenses that were inadvertently entered into the wrong accounting period due to a system issue which caused the expenses to be billed to the wrong grant period. Cause: The Organization’s system encountered an issue with the sync tool that is used to integrate mileage data from the organization’s payroll system. Effect: The Organization was not in compliance with the period of performance requirement since costs were charged to the grant prior to the start of the period of performance. Repeat Finding: No Recommendation: We recommend the Organization evaluate its procedures and implement an additional control to ensure costs are charged to the grant during the period of performance. Views of responsible officials: There is no disagreement with the audit finding. This was an exception and controls have been put in place to ensure that this does not re-occur.
Continuum of Care Program – Assistance Listing No. 14.267 Recommendation: We recommend the Organization evaluate its procedures and implement an additional control to ensure costs are charged to the grant during the period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Prior to 2023-2024, we only had one primary HUD contract that we were solely responsible for spending and contract timelines. With the addition of three more COC grants, with different, yet close together end dates, we needed to develop a more formalized process to ensure all expenses are billed to the correct contract for the correct dates. Avivo will implement oversight check-in meetings at least one month prior to each contract end and at least one more before final grant submissions. This meeting will include program leadership, RAA, Director of Housing Compliance, and our Contracts Accountant who oversees eLOCCS pulls. We will discuss all final expenditures and any upcoming expenses that may near the end of the grant term, including staff expenditures like mileage reimbursement. We will create an oversight document that highlights all areas to consider and breaks down roles and responsibilities to drive these meetings ongoingly. Accounting and program leadership will closely monitor spending via Papersave, credit card submission and through Paycom falls within the correct payment periods. Additionally, the RAA and Program Managers in the last quarter of the grant cycle, will meet monthly to work to resolve any outstanding rent balances and oversee any staff reimbursement or other charges that may need to be accounted for. Name(s) of the contact person(s) responsible for corrective action: Courtney Knoll & Lyssa Westling. Planned completion date for corrective action plan: December 2025
The Organization submitted the financial report after the required due date and the performance report did not have evidence of review or approval. Questioned costs: None Context: During our testing, we identified the financial report was submitted after the required due date and the performance report did not have evidence of review or approval. Cause: The Organization did not submit financial report timely and performance report did not have evidence of control. Effect: The Organization did not meet the reporting requirements for submitting financial reports timely. Additionally, one performance report did not have evidence of a review performed. Repeat Finding: No Recommendation: We recommend the entity evaluate its procedures and implement an additional control to ensure reports are submitted timely and reviewed prior to submission.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.243 Federal Award Identification Number and Year: H79TI080845 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: January 1, 2024 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reimbursement requests are formally reviewed by someone who did not prepare the request to verify the correct information and data is submitted. Condition: The Organization submitted the financial report after the required due date and the performance report did not have evidence of review or approval. Questioned costs: None Context: During our testing, we identified the financial report was submitted after the required due date and the performance report did not have evidence of review or approval. Cause: The Organization did not submit financial report timely and performance report did not have evidence of control. Effect: The Organization did not meet the reporting requirements for submitting financial reports timely. Additionally, one performance report did not have evidence of a review performed. Repeat Finding: No Recommendation: We recommend the entity evaluate its procedures and implement an additional control to ensure reports are submitted timely and reviewed prior to submission.
Substance Abuse and Mental Health Services Projects of Regional and National Significance – Assistance Listing No. 93.243 Recommendation: We recommend the entity evaluate its procedures and implement an additional control to ensure reports are submitted timely and reviewed prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Avivo will implement an enhanced internal review process to ensure timely report submission and accuracy prior to submission. This will include assigning dedicated personnel to track submission deadlines and conducting pre-submission reviews for completeness and accuracy. Name(s) of the contact person(s) responsible for corrective action: Heidi Kammer-Hodge & Kristen Bewley. Planned completion date for corrective action plan: December 2025.
FAC accepted this audit on June 18, 2024 — management decision was due December 18, 2024.
FAC accepted this audit on September 28, 2023 — management decision was due March 28, 2024.
FAC accepted this audit on April 25, 2022 — management decision was due October 25, 2022.
FAC accepted this audit on April 11, 2021 — management decision was due October 11, 2021.
FAC accepted this audit on May 3, 2020 — management decision was due November 3, 2020.
FAC accepted this audit on March 21, 2019 — management decision was due September 21, 2019.
FAC accepted this audit on April 22, 2018 — management decision was due October 22, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on April 29, 2017 — management decision was due October 29, 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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