EIN: 411302487
UEI: FMHNL5YV7CB8
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 12, 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 September 12, 2026 (21 days from today).
What is a management decision? →During our testing, we identified eight instances where the participant’s file had incomplete or inaccurate documentation of review and approval for the rent reasonableness test. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 10 tenants were selected out of 56 tenants for rent reasonableness testing. Repeat Finding from Prior Years: Yes, 2024-001 Recommendation: We recommend management revise their internal control procedures with applicable employees to make sure that all rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Federal awards MN0238L5K002209, MN0238L5K002310, MN0448L5K002203, MN0448L5K002304, MN0457L5K012203, MN0457L5K012304, MN0449L5K002201, and MN0449L5K002302 included under Federal Financial Assistance Listing 14.267 on the Schedule Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified eight instances where the participant’s file had incomplete or inaccurate documentation of review and approval for the rent reasonableness test. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 10 tenants were selected out of 56 tenants for rent reasonableness testing. Repeat Finding from Prior Years: Yes, 2024-001 Recommendation: We recommend management revise their internal control procedures with applicable employees to make sure that all rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.
Finding 2025-002 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being reviewed before the rent was paid. Corrective Action Plan: The Senior Division Director (now VP of Housing) issued the Rent Reasonableness Policy (Scattered Sites) on May 14, 2025. This policy was approved by the CEO on June 3, 2025, and was disseminated to all applicable staff via the Learning Management System (Bridge). Staff are required to read and electronically sign acknowledgement of every policy sent to them via Bridge. Managers in the Scattered Site program were trained on the policy and procedure in July 2025. To ensure compliance with this policy, the VP of Housing will audit all client files at least twice annually. The first audit is scheduled for March 11, 2026. Results of the internal audit will be shared with the Compliance Department for further assessment and action. Responsible Individuals: Kristen Brown, Vice-President of Housing Anticipated Completion Date: March 31, 2026
2024-001
Catholic Charities has documented procurement and suspension and debarment procedures that conform to applicable federal standards regarding procurement and testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing for procurement and one for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding the process of obtaining quotes to support procurement and testing vendors for suspension and debarment were followed. Effect: Payments could be made to vendors who have higher costs than other vendors or who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 17 vendors out of 83 total transactions were selected for testing, which accounted for $81,494 of $681,188 federal program expenditures. Repeat Finding from Prior Year(s): Yes, 2024-002 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all procurement and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement and suspension and debarment procedures that conform to applicable federal standards regarding procurement and testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing for procurement and one for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding the process of obtaining quotes to support procurement and testing vendors for suspension and debarment were followed. Effect: Payments could be made to vendors who have higher costs than other vendors or who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 17 vendors out of 83 total transactions were selected for testing, which accounted for $81,494 of $681,188 federal program expenditures. Repeat Finding from Prior Year(s): Yes, 2024-002 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all procurement and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Procurement Finding 2025-003 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Radias Health Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding the process of obtaining quotes to support procurement and testing vendors for suspension and debarment were followed. Corrective Action Plan: Catholic Charities is enhancing procurement oversight and compliance by centralizing procurement documentation, strengthening review and approval controls, and increasing management oversight. Procurement records will be centrally maintained and made accessible to the Accounting and Compliance Departments, in order to support monitoring and audit readiness. Updated training and standardized compliance tools are in the process of implementation, to reinforce consistent application of federal procurement requirements. In addition, Catholic Charities is strengthening vendor oversight through a centralized vendor management process that ensures ongoing monitoring for suspension and debarment. The Compliance Department already runs regular debarment/suspension checks against all vendors engaged in any form of agreement (e.g., contract, grant, MOU, amendment, etc.) but has no visibility to vendors not tied to an agreement. To solve this, the Compliance Department will request a report from the Accounting Department, which lists all vendors paid and will run debarment and suspension checks. All new vendors will be reviewed prior to engagement, and existing vendors will be reviewed on a recurring basis using this report. Responsible Individuals: Primary: Carys Church, Procurement Manager Secondary: Elizabeth Knight, Chief Compliance Officer; Mary Ammer, Sr. Director of Accounting and Finance Anticipated Completion Date: April 2026
2024-002
Catholic Charities has documented review procedures that conform to applicable federal standards regarding activities allowed or unallowed, allowable cost principles, matching, earmarking, and period of performance. However, the procedures were not followed for 34 of 60 selections for expense items, seven of 12 employees tested for payroll expenditures did not have documented approval on the allocation rate applied, as well as two of three months selected for testing for matching, earmarking, and indirect expenses. Additionally, for four of 12 employees errors in the payroll calculations were identified that were not corrected or identified by Catholic Charities and for one employee there was no evidence of approval on the hours paid for two pay periods during the year. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in transactions not being reviewed timely or the review process not being formally documented and maintained. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported.Context/Sampling: Activities Allowed or Unallowed/Allowable Cost Principles and Period of Performance: Expenses: A nonstatistical sample of 60 transactions out of 2,324 total transactions were selected for testing, which accounted for $23,406 of $681,188 federal program expenditures. Payroll expenses: A nonstatistical sample of 12 employees out of 61 were selected for testing, which accounted for $196,230 of $473,784 federal program expenditures. Indirect expenses: A nonstatistical sample of three months out of 12 were selected for testing. Matching and Earmarking: A nonstatistical sample of three months out of 12 were selected for testing. Repeat Finding from Prior Year(s): No Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Activities Allowed or Unallowed/Allowable Cost Principles, Matching and Earmarking, Period of Performance Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Internal control procedures should ensure expenses and other records tracking allowable costs, allowable activities, period of performance, indirect expenses, matching and earmarking are approved and the approval is documented in a timely manner. Condition: Catholic Charities has documented review procedures that conform to applicable federal standards regarding activities allowed or unallowed, allowable cost principles, matching, earmarking, and period of performance. However, the procedures were not followed for 34 of 60 selections for expense items, seven of 12 employees tested for payroll expenditures did not have documented approval on the allocation rate applied, as well as two of three months selected for testing for matching, earmarking, and indirect expenses. Additionally, for four of 12 employees errors in the payroll calculations were identified that were not corrected or identified by Catholic Charities and for one employee there was no evidence of approval on the hours paid for two pay periods during the year. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in transactions not being reviewed timely or the review process not being formally documented and maintained. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported.Context/Sampling: Activities Allowed or Unallowed/Allowable Cost Principles and Period of Performance: Expenses: A nonstatistical sample of 60 transactions out of 2,324 total transactions were selected for testing, which accounted for $23,406 of $681,188 federal program expenditures. Payroll expenses: A nonstatistical sample of 12 employees out of 61 were selected for testing, which accounted for $196,230 of $473,784 federal program expenditures. Indirect expenses: A nonstatistical sample of three months out of 12 were selected for testing. Matching and Earmarking: A nonstatistical sample of three months out of 12 were selected for testing. Repeat Finding from Prior Year(s): No Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management agrees with the finding.
Grant Accounting Finding 2025-004 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Radias Health* Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities’ internal controls did not operate as designed, which resulted in transactions not being reviewed timely or the review process not being formally documented and maintained. Corrective Action Plan: CCSPM is expanding the monthly secondary review of Continuum of Care grants to include matching grant requirements, de minimis rates and administrative expenses to ensure compliance with uniform guidance. The expanded review process will include the evidencing of each criteria reviewed. A senior member of the Accounting Team will perform the review. Responsible Individuals: Mary Ammer, Senior Director of Accounting and Finance and Grant Accountants: Jen Goeppinger and Ashley Feldick. Anticipated Completion Date: A secondary review of each Continuum of Care grant will be performed under these expanded criteria for the period of 7.25-12.25 and monthly beginning with January 2026 and thereafter. *The Radias Health pass-through ended early in FY2025. The correction action outlined above will be applied across existing active Continuum of Care grants.
Catholic Charities has documented review procedures that conform to applicable federal standards regarding indirect expenses; however, the procedures failed to detect that indirect costs were billed at the wrong rate as allowed under uniform guidance. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the de minimis rates were appropriately billed as allowed under uniform guidance. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of three months out of 12 were selected for testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all indirect cost are correctly calculated and billed. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Federal awards MN0308L5K012209, MN0203L5K002308, MN0399L5K012205, MN0448L5K002203, MN0457L5K012203, and MN0449L5K002302 included under Federal Financial Assistance Listing 14.267 on the Schedule Activities Allowed or Unallowed/Allowable Cost Principles and Period of Performance Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Catholic Charities has documented review procedures that conform to applicable federal standards regarding indirect expenses; however, the procedures failed to detect that indirect costs were billed at the wrong rate as allowed under uniform guidance. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the de minimis rates were appropriately billed as allowed under uniform guidance. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of three months out of 12 were selected for testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all indirect cost are correctly calculated and billed. Views of Responsible Officials: Management agrees with the finding.
Grant Accounting Finding 2025-005 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the de minimis rates were appropriately billed as allowed under uniform guidance. Corrective Action Plan: CCSPM will adhere to uniform guidance specific to de minimis rates ensuring Indirect Expenses are no more than allowable percentage of eligible total expenses over the grant period. Adherence will be monitored as part of an expanded monthly secondary review process across Continuum of Care grants. Responsible Individuals: Mary Ammer, Senior Director of Accounting and Finance and Grant Accountants: Jen Goeppinger and Ashley Feldick. Anticipated Completion Date: Allowable de minimis rates will be met by the end of the current grant period or end of FY26 (6.30.26), whichever is sooner for each currently active Continuum of Care grant.
Catholic Charities has documented review procedures that conform to applicable federal standards regarding earmarking; however, the procedures failed to detect that administrative costs billed exceeded the 10% allowed under uniform guidance. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the administrative costs were appropriately billed as allowed under uniform guidance. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: MN0308L5K012310 for $7,709; MN0203L5K002308 for $1,480; MN0203L5K002409 for $139; MN0399L5K012306 for $5,679; MN0448L5K002203 for $1,065; and MN0448L5K002304 for $1,234 Context/Sampling: A nonstatistical sample of three months out of 12 were selected for testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all administrative costs are correctly calculated and billed. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Federal awards MN0308L5K012310, MN0203L5K002308, MN0203L5K002409, MN0399L5K012306, MN0448L5K002203, and MN0448L5K002304 included under Federal Financial Assistance Listing 14.267 on the Schedule Earmarking Material Weakness in Internal Control Over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Catholic Charities has documented review procedures that conform to applicable federal standards regarding earmarking; however, the procedures failed to detect that administrative costs billed exceeded the 10% allowed under uniform guidance. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the administrative costs were appropriately billed as allowed under uniform guidance. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: MN0308L5K012310 for $7,709; MN0203L5K002308 for $1,480; MN0203L5K002409 for $139; MN0399L5K012306 for $5,679; MN0448L5K002203 for $1,065; and MN0448L5K002304 for $1,234 Context/Sampling: A nonstatistical sample of three months out of 12 were selected for testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all administrative costs are correctly calculated and billed. Views of Responsible Officials: Management agrees with the finding.
Grant Accounting Finding 2025-006 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the administrative costs were appropriately billed as allowed under uniform guidance. Corrective Action Plan: CCSPM will adhere to uniform guidance specific to Administrative Expenses ensuring Administrative Expenses plus Indirect Expenses are no more than 10% of the total award over the grant period. Adherence will be monitored as part of an expanded monthly secondary review process across Continuum of Care grants. Responsible Individuals: Mary Ammer, Senior Director of Accounting and Finance and Grant Accountants: Jen Goeppinger and Ashley Feldick. Anticipated Completion Date: Adherence will be met by the end of the current grant period or end of FY26 (6.30.26), whichever is sooner for each currently active Continuum of Care grant.
FAC accepted this audit on January 16, 2025 — management decision was due July 16, 2025.
During our testing, we identified 4 instances where the participant’s file either did not have documentation that the rent reasonableness test was reviewed, or the documentation regarding the rent reasonableness test was incomplete or inaccurate. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in incomplete/inaccurate rent reasonableness documentation and lack of review before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 38 tenants were selected out of 100 tenants receiving rent payments from federal funds which made up $30,332 of $646,182 federal awards. Repeat Finding from Prior Years: Yes, 2023-003 Recommendation: We recommend management revise their internal control procedures with applicable employees to make sure that all rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified 4 instances where the participant’s file either did not have documentation that the rent reasonableness test was reviewed, or the documentation regarding the rent reasonableness test was incomplete or inaccurate. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in incomplete/inaccurate rent reasonableness documentation and lack of review before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 38 tenants were selected out of 100 tenants receiving rent payments from federal funds which made up $30,332 of $646,182 federal awards. Repeat Finding from Prior Years: Yes, 2023-003 Recommendation: We recommend management revise their internal control procedures with applicable employees to make sure that all rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.
Finding Summary: Catholic Charities internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid for two of the transactions reviewed by the auditors. Corrective Action Plan: The organization’s Sr Division Director Housing Stability will implement a rent reasonableness completion and review process. Responsible Individuals: Chief Program Officer Anticipated Completion Date: June 30, 2025
2023-003
Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Finding Summary: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Corrective Action Plan: Procurement, suspension and debarment procedures were largely decentralized across the agency. In response, the organization has an internal, cross-functional compliance team that has reviewed and is developing process changes to ensure appropriate systems are developed and documentation is maintained for purchasing related to federal programs. Responsible Individuals: Chief Legal Officer, Controller Anticipated Completion Date: June 30, 2025
2023-001
FAC accepted this audit on January 18, 2024 — management decision was due July 18, 2024.
Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance and Other Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of 32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Years: Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management is in agreement with this finding.
Procurement, suspension and debarment procedures were largely decentralized across the agency. In response, the organization has an internal, cross-functional compliance team that has reviewed and is developing process changes to ensure appropriate systems are developed and documentation is maintained for purchasing related to federal programs.
2022-001
For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.
Show full finding ▾Hide full finding ▴Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities’ ability to support compliance with reporting requirements. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: Yes Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.
A review of required reports will be done for each federal grant and the appropriate staff will be assigned to review and approve reports prior to submission.
2022-002
During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267 Special Tests Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 on the Schedule. Criteria: When grant funds are used by Catholic Charities to pay for rent, Catholic Charities must ensure that the rents do not exceed rents currently being charged by the same owner for comparable unassisted units and the portion of grant funds may not exceed HUD-determined fair market rents. These calculations should be reviewed prior to the rent being paid. Condition: During our testing, we identified nine instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent was paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 were selected out of 510 rent payments that were paid. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure that rent reasonableness tests are performed and reviewed by the appropriate personnel prior to the rent being paid. Views of Responsible Officials: Management is in agreement with this finding.
The organization’s Sr Division Director Housing Stability will implement a rent reasonableness completion and review process.
FAC accepted this audit on January 17, 2023 — management decision was due July 17, 2023.
Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported Context/Sampling: For Federal Financial Assistance Listing 14.231, a nonstatistical sample of 29 transactions out of 158 total transactions were selected for testing. Required documentation related to procurement was not maintained for three of the items selected, and six of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 16 transactions out of 82 total transactions were selected for testing. Required documentation related to procurement was not maintained for 4 of the items selected, and seven of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Year(s): Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-001 Department of Housing and Urban Development Emergency Solutions Grants Program, Federal Financial Assistance Listing 14.231 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.231 and 21.027 on the Schedule. Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment. Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported Context/Sampling: For Federal Financial Assistance Listing 14.231, a nonstatistical sample of 29 transactions out of 158 total transactions were selected for testing. Required documentation related to procurement was not maintained for three of the items selected, and six of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 16 transactions out of 82 total transactions were selected for testing. Required documentation related to procurement was not maintained for 4 of the items selected, and seven of the items selected did not have support for suspension, and debarment. Repeat Finding from Prior Year(s): Yes Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Single Audit Finding 2022-001 Federal Agency Name: Department of Housing and Urban Development, Department of Treasury Program Name: Emergency Solutions Grant Program, Coronavirus State and Local Fiscal Recovery Funds Program CFDA # 14.231, 21.027 Finding Summary: Management did not have adequate internal controls in place to ensure that the process laid out in their procurement, suspension, and debarment policy were followed. Responsible Individuals: Thomas Krolak Corrective Action Plan: The organization has recently updated the purchasing policies and is reviewing process changes in order to ensure appropriate documentation is maintained for purchasing related to federal programs. Anticipated Completion Date: June 30, 2023
2021-003
For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities? ability to support compliance with reporting requirements. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.
Show full finding ▾Hide full finding ▴2022-002 Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027 Reporting Significant Deficiency in Internal Control Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 21.027 on the Schedule. Criteria: Internal control procedures should ensure all required reports are reviewed prior to submission. Condition: For two reports submitted, there was no formal documentation of the review prior to submission. Cause: Catholic Charities has designed internal controls over these areas; however, the controls were not formally documented. Effect: The condition may affect the Catholic Charities? ability to support compliance with reporting requirements. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of two reports out of four were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend the procedures related to reporting be reviewed with applicable program employees to ensure the control process is properly supported and the documentation is retained. Views of Responsible Officials: Management is in agreement with this finding.
Finding 2022-002 Federal Agency Name: Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds Program CFDA # 21.027 Finding Summary: Management has designed internal controls related to reporting, however, the controls were not formally documented. Responsible Individuals: Thomas Krolak Corrective Action Plan: A review of required reports will be done for each federal grant and the appropriate staff will be assigned to review and approved reports prior to submission Anticipated Completion Date: June 30, 2023
FAC accepted this audit on January 20, 2022 — management decision was due July 20, 2022.
For two of the three vendors selected for procurement testing, we noted written documentation on the selection method was not retained in the procurement file. For one of the three vendors selected for suspension and debarment testing did not have documentation retained. Questioned costs: N/A Context: Two out of three items selected for testing of procurement did not have proper documentation of procurement. One out of three items selected for testing of suspension and debarment did not have proper documentation. The sample was determined to be a statistically valid sample. Cause: Written support was not retained in the procurement file at the time of the procurement. Support for the suspension and debarment was not retained in the file. Effect: Procuring vendors without full and open competition. Entering into a transaction with a vendor that has been suspended or debarred. Repeat Finding: No Recommendation: Auditor recommends the Organization review the various requirements involved with procurement and suspension and debarment requirements with the individuals involved in this process to ensure they understand the requirements. It is also recommended to review the policies and procedures around procurement to ensure key individuals are following them.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Uniform Guidance section 200.318 states non-federal entities must maintain records sufficient to detail the history of procurements. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The non-federal entity also must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: For two of the three vendors selected for procurement testing, we noted written documentation on the selection method was not retained in the procurement file. For one of the three vendors selected for suspension and debarment testing did not have documentation retained. Questioned costs: N/A Context: Two out of three items selected for testing of procurement did not have proper documentation of procurement. One out of three items selected for testing of suspension and debarment did not have proper documentation. The sample was determined to be a statistically valid sample. Cause: Written support was not retained in the procurement file at the time of the procurement. Support for the suspension and debarment was not retained in the file. Effect: Procuring vendors without full and open competition. Entering into a transaction with a vendor that has been suspended or debarred. Repeat Finding: No Recommendation: Auditor recommends the Organization review the various requirements involved with procurement and suspension and debarment requirements with the individuals involved in this process to ensure they understand the requirements. It is also recommended to review the policies and procedures around procurement to ensure key individuals are following them.
Recommendation: The Organization review the various requirements involved with procurement and suspension and debarment requirements with the individuals involved in this process to ensure they understand the requirements. It is also recommended to review the policies and procedures around procurement to ensure key individuals are following them. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The organization has recently updated the purchasing policies and is reviewing process changes in order to ensure appropriate documentation is maintained for purchasing related to federal programs. Name(s) of the contact person(s) responsible for corrective action: Thomas Krolak, Controller
FAC accepted this audit on January 14, 2019 — management decision was due July 14, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on November 3, 2016 — management decision was due May 3, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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