EIN: 411669233
UEI: RCNTN5GKRQ61
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 26, 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 December 26, 2025 (242 days ago).
What is a management decision? →During our testing, we identified five instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner or reviewed for compliance with the grant period of performance. In addition, we identified 32 instances where the participant’s file did not have documentation that the rent reasonableness test was reviewed. Cause: The Organization’s 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: N/A Context/Sampling: A nonstatistical sample of 32 participants out of 160 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2023-002. 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 agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development, Passed through Hearth Connections and Passed through Dakota County, Continuum of Care, Federal Financial Assistance Listing #14.267 Special Tests and Provisions, Period of Performance Material Weakness in Internal Controls Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule. Criteria: When grant funds are used by the Organization to pay for rent, the Organization 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 and the review should also make sure the proper period of performance. Condition: During our testing, we identified five instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner or reviewed for compliance with the grant period of performance. In addition, we identified 32 instances where the participant’s file did not have documentation that the rent reasonableness test was reviewed. Cause: The Organization’s 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: N/A Context/Sampling: A nonstatistical sample of 32 participants out of 160 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2023-002. 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 agrees with the finding.
Finding 2024-002 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Passed through Hearth Connections and Passed through Dakota County, Continuum of Care. Assistance Listing Number: Federal Financial Assistance Listing #14.267 Program Name: Continuum of Care Program Finding Summary: Guild’s controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent being paid. Corrective Action Plan: This clinical program is now under new leadership and is enhancing its controls and oversight. In addition to requiring a monthly rent checklist to be reviewed and signed off by the responsible official, an additional layer of control will be implemented by involving Finance in verifying that proper documentation is in place before rent checks are issued. The program, in collaboration with Finance, will also continue enhancing the approach to standardized documentation. Responsible Individuals: Keith Rachey - Chief Financial Officer, Tiffany Yang – Controller, Diana Harris – Director of Clinical Services Anticipated Completion Date: Completed by September 2025
2023-002
FAC accepted this audit on July 1, 2024 — management decision was due January 1, 2025.
During our testing, we identified three instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner or reviewed for compliance with the grant period of performance. In addition, we identified 23 instances where the participant’s file did not have documentation that the rent reasonableness test was reviewed. Cause: The Organization’s controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent being paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of 33 participants out of 161 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2022-001. 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 agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development, Passed through Hearth Connections and Passed through Dakota County, Continuum of Care, Federal Financial Assistance Listing #14.267 Special Tests and Provisions, Period of Performance Material Weakness in Internal Controls Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule. Criteria: When grant funds are used by the Organization to pay for rent, the Organization 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 and the review should also make sure the proper period of performance. Condition: During our testing, we identified three instances where the participant’s file did not have documentation that the rent reasonableness test was performed in a timely manner or reviewed for compliance with the grant period of performance. In addition, we identified 23 instances where the participant’s file did not have documentation that the rent reasonableness test was reviewed. Cause: The Organization’s controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent being paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of 33 participants out of 161 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2022-001. 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 agrees with the finding.
Finding Summary: Guild’s controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent being paid. Corrective Action Plan: Working with all Rental Assistance staff, we will develop a standard for documentation and a checklist for signing off by the responsible official. Responsible Individuals: Keith Rachey, Chief Financial Officer Anticipated Completion Date: Completed and staff trained by September 2024
2022-001
During our testing, we identified one month in which the reimbursement amount received from the pass‐through entity was more than the Organization’s documentation. Cause: The Organization’s controls did not operate as designed, which resulted in the reimbursement amount from the pass‐through entity being more than the support maintained by the Organization for one of the 12 months. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of four months participants out of 12 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2022-002. Recommendation: We recommend management revise their internal controls to make sure the forms submitted are reviewed by the Organization prior to submission. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development, Passed through Hearth Connections Continuum of Care, Federal Financial Assistance Listing #14.267 Period of Performance Significant Deficiency in Internal Controls Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule passed through Hearth Connections. Criteria: Internal controls should be designed and operating to ensure that documentation that is maintained by the Organization that supports the reimbursement amount received from the passthrough entity for supportive services. Condition: During our testing, we identified one month in which the reimbursement amount received from the pass‐through entity was more than the Organization’s documentation. Cause: The Organization’s controls did not operate as designed, which resulted in the reimbursement amount from the pass‐through entity being more than the support maintained by the Organization for one of the 12 months. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of four months participants out of 12 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2022-002. Recommendation: We recommend management revise their internal controls to make sure the forms submitted are reviewed by the Organization prior to submission. Views of Responsible Officials: Management agrees with the finding.
Finding Summary: Guild’s controls did not operate as designed, which resulted in overbilling reimbursement for services in one month during 2023. Corrective Action Plan: Each receipt from this payer will be reconciled with the general ledger in the month received. In addition, the payer is modifying their payment support to show any payer-initiated adjustments. Responsible Individuals: Keith Rachey, Chief Financial Officer Anticipated Completion Date: Completed and staff trained by September 2024
2022-002
FAC accepted this audit on July 9, 2023 — management decision was due January 9, 2024.
During our testing, we identified five instances where the participant?s file did not have documentation that the rent reasonableness test was performed in a timely manner. In addition, we identified 19 instances where the participant?s file did not have documentation that the rent reasonableness test was reviewed. Cause: The Organization?s controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent being paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of 34 participants out of 170 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2021-002. 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 agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development, Passed through Hearth Connections, Continuum of Care, Federal Financial Assistance Listing/CFDA # 14.267 Special Tests and Provisions Material Weakness in Internal Controls 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 the Organization to pay for rent, the Organization 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 five instances where the participant?s file did not have documentation that the rent reasonableness test was performed in a timely manner. In addition, we identified 19 instances where the participant?s file did not have documentation that the rent reasonableness test was reviewed. Cause: The Organization?s controls did not operate as designed, which resulted in rent reasonableness tests not being performed timely and/or reviewed before the rent being paid. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of 34 participants out of 170 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2021-002. 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 agrees with the finding.
Finding 2022-001 Federal Agency Name: Department of Housing and Urban Development, Passed through Hearth Connections Program Name: Continuum of Care CFDA # 14.267 Finding Summary: Identified five instances where the participant?s file did not have documentation that the rent reasonableness test was performed in a timely manner. In addition, we identified 19 instances where the participant?s file did not have documentation that the rent reasonableness test was reviewed. Creating Inadequate internal controls over compliance could result in noncompliance with the federal program. Responsible Individuals: Paul Bloomer, VP of Finance Corrective Action Plan: A complete review and policy and procedures along with proper training for new staff. The findings occurred during position vacancy and onboarding training. Additional steps are taken to ensure training is completed and random spot checks of client files. Anticipated Completion Date: Ongoing in nature.
2021-002
During our testing, we identified three months in which the reimbursement amount received from the pass-through entity was more than the Organization?s documentation. In addition, there was no indication that a review was performed of the information submitted for one of the four months tested. Cause: The Organization?s controls did not operate as designed, which resulted in the reimbursement amount from the pass-through entity being more than the support maintained by the Organization for three of the 12 months and no documentation of the review for one of the months. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of four months participants out of 12 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2021-003. Recommendation: We recommend management revise their internal controls to make sure the forms submitted are reviewed by the Organization prior to submission. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Housing and Urban Development, Passed through Hearth Connections, Continuum of Care, Federal Financial Assistance Listing/CFDA # 14.267 Period of Performance Significant Deficiency in Internal Controls Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/ CFDA 14.267 on the Schedule. Criteria: Internal controls should be designed and operating to ensure that documentation that is maintained by the Organization that supports the reimbursement amount received from the passthrough entity for supportive services. Condition: During our testing, we identified three months in which the reimbursement amount received from the pass-through entity was more than the Organization?s documentation. In addition, there was no indication that a review was performed of the information submitted for one of the four months tested. Cause: The Organization?s controls did not operate as designed, which resulted in the reimbursement amount from the pass-through entity being more than the support maintained by the Organization for three of the 12 months and no documentation of the review for one of the months. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of four months participants out of 12 were selected for testing. Repeat Finding from Prior Years: Yes, prior year finding 2021-003. Recommendation: We recommend management revise their internal controls to make sure the forms submitted are reviewed by the Organization prior to submission. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-002 Federal Agency Name: Department of Housing and Urban Development, Passed through Hearth Connections Program Name: Continuum of Care CFDA # 14.267 Finding Summary: Identified three months in which the reimbursement amount received from the pass-through entity was more than the Organization?s documentation. In addition, there was no indication that a review was performed of the information submitted for one of the four months tested, which resulted in the reimbursement amount from the pass-through entity being more than the support maintained by the Organization for three of the 12 months and no documentation of the review for one of the months. Responsible Individuals: Paul Bloomer, VP of Finance Corrective Action Plan: Schedule meetings with 3rd party vendor to identify the significant rounding errors occurring. Develop an agreement on rounding procedures to be used by both parties ensuring reconciliation. Anticipated Completion Date: 12/31/23 ? Note- this system of reimbursement terminated on 3/31/23
2021-003
FAC accepted this audit on June 27, 2022 — management decision was due December 27, 2022.
During our engagement, we identified seven instances where the participant?s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: The Organization?s controls did not operate as designed, which resulted in rent reasonableness documentation not being performed timely. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of 35 participants out of 176 were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure the forms are reviewed and signed by the Organization prior to rent being paid. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2021-002 Department of Housing and Urban Development, Passed through Hearth Connections, Continuum of Care, Federal Financial Assistance Listing/CFDA # 14.267 Special Tests and Provisions Material Weakness in Internal Controls 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 the Organization to pay for rent, the Organization must ensure that the rents 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. Condition: During our engagement, we identified seven instances where the participant?s file did not have documentation that the rent reasonableness test was performed in a timely manner. Cause: The Organization?s controls did not operate as designed, which resulted in rent reasonableness documentation not being performed timely. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of 35 participants out of 176 were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure the forms are reviewed and signed by the Organization prior to rent being paid. Views of Responsible Officials: Management agrees with the finding.
Single Audit Finding 2021-002 Federal Agency Name: Department of Housing and Urban Development Program Name: Continuum of Care CFDA #14.267 Finding Summary: During the audit seven instances where the participant?s file did not have documentation that the rent reasonableness test was performed in a timely manner. Responsible Individuals: Paul Bloomer, Director of Finance Corrective Action Plan: We have updated our policy and procedures to ensure client files are updated timely with the appropriate documentation maintained. Documentation for rent reasonableness is now part approval process before payments are issued. In addition, the agency is currently reviewing controls throughout the agency and program Anticipated Completion Date: Ongoing
During our engagement, we identified three months in which the reimbursement amount received from the pass-through entity did not agree to the Organization?s documentation. In addition, there was no indication that a review was performed of the information. Cause: The Organization?s controls did not operate as designed, which resulted in the reimbursement amount from the pass-through entity not agreeing to the support maintained by the Organization. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of four months participants out of 12 were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure the forms submitted are reviewed by the Organization prior to submission. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2021-003 Department of Housing and Urban Development, Passed through Hearth Connections, Continuum of Care, Federal Financial Assistance Listing/CFDA # 14.267 Period of Performance Significant Deficiency in Internal Controls Over Compliance Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/ CFDA 14.267 on the Schedule. Criteria: Internal controls should be designed and operating to ensure that documentation that is maintained by the Organization supports the reimbursement amount received from the pass-through entity for supportive services. Condition: During our engagement, we identified three months in which the reimbursement amount received from the pass-through entity did not agree to the Organization?s documentation. In addition, there was no indication that a review was performed of the information. Cause: The Organization?s controls did not operate as designed, which resulted in the reimbursement amount from the pass-through entity not agreeing to the support maintained by the Organization. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: N/A Context/Sampling: A nonstatistical sample of four months participants out of 12 were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend management revise their internal controls to make sure the forms submitted are reviewed by the Organization prior to submission. Views of Responsible Officials: Management agrees with the finding.
Finding 2021-003 Federal Agency Name: Department of Housing and Urban Development Program Name: Continuum of Care CFDA #14.267 Finding Summary: During the audit three months in which the reimbursement amount received from the pass-through entity did not agree to the Organization?s documentation. In addition, there was no indication that a review was performed of the information. Responsible Individuals: Paul Bloomer, Director of Finance Corrective Action Plan: Manual reconciliation process developed interim, new systems to be developed to better reconcile submission to payments. Development of system will coordinate with above mentioned 3rd party report writing system in an electronic format. In addition, the agency is currently reviewing controls throughout the agency and program Anticipated Completion Date: Ongoing 2022
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