Brevard Homeless Coalition

EIN: 471533071

UEI: C2JCKD4VNF13

Data as of August 20, 2026

5
Audit Years
6
Total Findings
3
Repeat Findings

FY 2022-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 24, 2023. 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 24, 2023, which was (1061 days ago).

What is a management decision? →
2022-004
Activities Allowed or Unallowed / Cost Allowability
REPEATMATERIAL WEAKNESS
Condition

MW 2022-004 Review of Reimbursement Requests and Expenses Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reimbursement requests and monthly expense reports should be subject to independent review to verify the completeness and accuracy of the request and attached support. Condition: Detail attached to the reimbursement requests and monthly expense reports did not consistently support the amount requested for reimbursement. Detail attached to the reimbursement requests and monthly expense reports did not consistently support the amount requested for reimbursement. Individual payroll and non-payroll expenses were not consistently subject to review for allowability. Cause: Staff mistakenly omitted required support or input incorrect amounts. Staff mistakenly submitted a disallowed expense within a reimbursement request discovered by the pass through entity. Effect: A reimbursement request included errors and unsupported expenses. The grantor identified the errors and omissions and required the reimbursement request be resubmitted with the corrections and required support. The Organization did not have procedures to document the review of individual payroll and non-payroll expenses for allowability. Questioned Costs: None Perspective: The Executive Director has implemented procedures to organize reimbursement request and monthly expense documentation to make it easier to ensure the completeness and accuracy of the submissions to the grantor. However, these documents are often very long, and human error may not be completely avoidable through the current method of documentation. Recommendation: Review of reimbursement requests and monthly expense submissions should be documented and ensure the completeness and accuracy of the submission. Review of individual payroll and non-payroll expense allowability should be documented. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. We have already implemented the recommended process for the review of reimbursement requests and monthly expense submissions. These are documented to ensure the completeness and accuracy of the submission. We also implemented the documentation of the review of individual payroll and non-payroll expense allowability. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit.

Corrective Action Plan

MW 2022-004 Review of Reimbursement Requests and Expenses Recommendation: Review of reimbursement requests and monthly expense submissions should be documented and ensure the completeness and accuracy of the submission. Review of individual payroll and non-payroll expense allowability should be documented. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. We have already implemented the recommended process for the review of reimbursement requests and monthly expense submissions. These are documented to ensure the completeness and accuracy of the submission. We also implemented the documentation of the review of individual payroll and non-payroll expense allowability. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. RESPONSIBLE PARTY - AMBER CARROLL

Prior Finding References

2021-006

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2022-005
Matching, Level of Effort, Earmarking
REPEAT
Condition

SD 2022-005 Support for Matching Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 24 CFR 576.201 specifies the recipient must make matching contributions to supplement the recipient's ESG program in an amount that equals the recipient's fiscal year grant for ESG. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The sources of matching funds, required by awards, should be documented and retained. Condition: Subrecipient requests for reimbursement did not include detail support for matching funds. Cause: At the outset of the award, subrecipients specify the types of match (cash, in-kind, service, use of facilities, etc.) they will provide for the award and they provide the amount of the match for each month on the monthly invoice/request for reimbursement. However, no support is provided for the type, quantity, or value of match during the month. Effect: The required matching funds may not be obtained for the award. Questioned Costs: None Perspective: Support for matching was not obtained for any subrecipients. Recommendation: Sources of and detail support for matching funds should be obtained prior to payment of subrecipient requests for reimbursement. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. The FY 20-21 Audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. We require match documentation to be provided upfront during the competitive RFP. We detailed in each sub-recipient contract the Match requirements that ensure compliance with 24 CFR 576.201 and 2 CFR 200.303. We have added a match reporting requirement to the invoicing process that requires proof of Match monthly. These sub-recipient contracts went into effect July 1, 2022 making the implementation of the recommended change effective outside of the fiscal year in review. This finding will be cleared in our next audit.

Corrective Action Plan

SD 2022-005 Support for Matching Recommendation: Sources of and detail support for matching funds should be obtained prior to payment of subrecipient requests for reimbursement. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. The FY 20-21 Audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. We require match documentation to be provided upfront during the competitive RFP. We detailed in each sub-recipient contract the Match requirements that ensure compliance with 24 CFR 576.201 and 2 CFR 200.303. We have added a match reporting requirement to the invoicing process that requires proof of Match monthly. These sub-recipient contracts went into effect July 1, 2022 making the implementation of the recommended change effective outside of the fiscal year in review. This finding will be cleared in our next audit. RESPONSIBLE PARTY - AMBER CARROLL

Prior Finding References

2021-007

About Matching, Level of Effort, Earmarking →
2022-006
Procurement & Suspension/Debarment
REPEAT
Condition

SD 2022-006 Subrecipient Procurement Policy Federal Award: 14.231 Emergency Solutions Grant Program 2022 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 2 CFR Part 180 prohibits award recipients from entering into covered transactions with vendors who are suspended or debarred. Further, 2 CFR 200.320 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Policies and procedures at subrecipient organizations should ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Condition: Subrecipients are required to have procurement policies which ensure competitive procurement and use vendors who are not suspended or debarred for grant-funded expenditures. Cause: The Organization has not developed a process to monitor this requirement for subrecipients. Effect: The Organization may reimburse subrecipients for transactions which did not comply with competitive procurement requirements or were made with suspended or debarred vendors. Questioned Costs: None Perspective: The Organization has competitive procurement procedures and verifies vendors are in good-standing for their grant-funded expenses. Procurement policies at subrecipients have not been required to be provided or evaluated. Recommendation: Prior to approving funding to a subrecipient, and annually thereafter, the Organization should require subrecipients to submit procurement policies which ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. We addressed the procurement policies with our existing subcontractors during their fiscal year 21-22 Monitoring visits in May, 2022. We added to any new and/or existing contracts the requirement for the Agency to supply their Procurement policies that ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. All new sub-recipient contracts that went into effect July 1, 2022 made the implementation of the recommended change effective outside of the fiscal year in review. This finding will be cleared in our next audit.

Corrective Action Plan

SD 2022-006 Subrecipient Procurement Policy Recommendation: Prior to approving funding to a subrecipient, and annually thereafter, the Organization should require subrecipients to submit procurement policies which ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. We addressed the procurement policies with our existing subcontractors during their fiscal year 21-22 Monitoring visits in May, 2022. We added to any new and/or existing contracts the requirement for the Agency to supply their Procurement policies that ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. All new sub-recipient contracts that went into effect July 1, 2022 made the implementation of the recommended change effective outside of the fiscal year in review. This finding will be cleared in our next audit. RESPONSIBLE PARTY - AMBER CARROLL

Prior Finding References

2021-008

About Procurement and Suspension and Debarment →

FY 2021-09-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on June 29, 2022. 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 29, 2022, which was (1330 days ago).

What is a management decision? →
2021-006
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESS
Condition

MW 2021-006 Review of Reimbursement Requests and Expenses Federal Award: 14.231 Emergency Solutions Grant Program 2020/2021 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reimbursement requests and monthly expense reports should be subject to independent review to verify the completeness and accuracy of the request and attached support. Condition: Detail attached to the reimbursement requests and monthly expense reports did not consistently support the amount requested for reimbursement. Individual payroll and non-payroll expenses were not consistently subject to review for allowability. Cause: Staff mistakenly omitted required support or input incorrect amounts. This was not identified during the review of the reimbursement request by the previous Executive Director. Effect: A reimbursement request included errors and unsupported expenses. The grantor identified the errors and omissions and required the reimbursement request be resubmitted with the corrections and required support. The Organization did not have procedures to document the review of individual payroll and non-payroll expenses for allowability. Questioned Costs: None Perspective: This error occurred during the tenure of the previous Executive Director working with staff who are no longer employed by the entity. The current Executive Director has implemented procedures to organize reimbursement request and monthly expense documentation to make it easier to ensure the completeness and accuracy of the submissions to the grantor. However, these procedures were not in place for the entire period under audit. The Executive Director has implemented procedures to document review of non-payroll expense transactions individually. Recommendation: Review of reimbursement requests and monthly expense submissions should be documented and ensure the completeness and accuracy of the submission. Review of individual payroll and non-payroll expense allowability should be documented. Management Response: We have already implemented the recommendation listed above to review reimbursement requests and monthly expense submissions through our Sharepoint and Docusign Procedures.

Corrective Action Plan

MW 2021-006 Review of Reimbursement Requests and Expenses Recommendation: Review of reimbursement requests and monthly expense submissions should be documented and ensure the completeness and accuracy of the submission. Review of individual payroll and non-payroll expense allowability should be documented. Management Response: We have already implemented the recommendation listed above to review reimbursement requests and monthly expense submissions through our Sharepoint and Docusign Procedures. Responsible Party- Amber Carroll Implementation Date- September 30, 2022

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-007
Matching, Level of Effort, Earmarking
Condition

SD 2021-007 Support for Matching Federal Award: 14.231 Emergency Solutions Grant Program 2020/2021 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 24 CFR 576.201 specifies the recipient must make matching contributions to supplement the recipient's ESG program in an amount that equals the recipient's fiscal year grant for ESG. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The sources of matching funds, required by awards, should be documented and retained. Condition: Subrecipient requests for reimbursement did not include detail support for matching funds. Cause: At the outset of the award, subrecipients specify the types of match (cash, in-kind, service, use of facilities, etc.) they will provide for the award and they provide the amount of the match for each month on the monthly invoice/request for reimbursement. However, no support is provided for the type, quantity, or value of match during the month. Effect: The required matching funds may not be obtained for the award. Questioned Costs: None Perspective: Support for matching was not obtained for any subrecipients. Recommendation: Sources of and detail support for matching funds should be obtained prior to payment of subrecipient requests for reimbursement. Management Response: We require match documentation to be provide upfront during the competitive RFP. We will detail in each sub-recipient contract the match requirements that ensure compliance with 24 CFR 576.201 and 2 CFR 200.303. We have added a match reporting requirement to the invoicing process that requires proof of match monthly.

Corrective Action Plan

SD 2021-007 Support for Matching Recommendation: Sources of and detail support for matching funds should be obtained prior to payment of subrecipient requests for reimbursement. Management Response: We require match documentation to be provided upfront during the competitive RFP. We will detail in each sub-recipient contract the Match requirements that ensure compliance with 24 CFR 576.201 and 2 CFR 200.303. We have added a match reporting requirement to the invoicing process that requires proof of Match monthly. Responsible Party- Amber Carroll Implementation Date- September 30, 2022

About Matching, Level of Effort, Earmarking →
2021-008
Procurement & Suspension/Debarment
Condition

SD 2021-008 Subrecipient Procurement Policy Federal Award: 14.231 Emergency Solutions Grant Program 2020/2021 Funding Department of Housing and Urban Development Passed through the Florida Department of Children and Families Contract No. GPZ48 Criteria: 2 CFR Part 180 prohibits award recipients from entering into covered transactions with vendors who are suspended or debarred. Further, 2 CFR 200.320 sets forth the requirements for acquisition contracts awarded to vendors including the requirement to obtain price or rate quotations from an adequate number of qualified sources and the circumstances in which noncompetitive procurement methods can be used. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Policies and procedures at subrecipient organizations should ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Condition: Subrecipients are required to have procurement policies which ensure competitive procurement and use vendors who are not suspended or debarred for grant-funded expenditures. Cause: The Organization has not developed a process to monitor this requirement for subrecipients. Effect: The Organization may reimburse subrecipients for transactions which did not comply with competitive procurement requirements or were made with suspended or debarred vendors. Questioned Costs: None Perspective: BHC has competitive procurement procedures and verifies vendors are in good-standing for their grant-funded expenses. Procurement policies at subrecipients have not been required to be provided or evaluated. Recommendation: Prior to approving funding to a subrecipient, and annually thereafter, the Organization should require subrecipients to submit procurement policies which ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Management Response: We have already addressed the procurement policies with out existing subcontractors during their FY 21-22 Monitoring visits. We have added to any new and/or existing competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures.

Corrective Action Plan

SD 2021-008 Subrecipient Procurement Policy Recommendation: Prior to approving funding to a subrecipient, and annually thereafter, the Organization should require subrecipients to submit procurement policies which ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Management Response: We have already addressed the procurement policies with our existing subcontractors during their FY 21-22 Monitoring visits. We have added to any new and/or existing contracts the requirement for the Agency to supply their Procurement policies that ensure competitive procurement and the use of vendors who are not suspended or debarred for grant-funded expenditures. Responsible Party- Amber Carroll Implementation Date- September 30, 2022

About Procurement and Suspension and Debarment →

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