BRADLEY ANGLENon-Profit

2025-001 Finding – Federal Awards – AL #93.592 – Family Violence Prevention and Services/ Discretionary Type: Significant Deficiency in Internal Control over Compliance – Financial Reporting Criteria / Requirement: 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition / Context: The Organization filed the required Federal Financial Report timely, the information reported was supported by detail within their general ledger, and there was no noncompliance noted. However, the Federal Financial Report was compiled and submitted by one employee. There was no internal control within the Federal Financial Reporting procedure that would have prevented or detected inaccurate information from being reported. Cause: Procedures were not in place to properly review Federal Financial Reporting prior to submission. Effect: Federal Financial Reporting could potentially include inaccurate information. Questioned Costs: None Recommendation: We recommend that the Organization implement the necessary internal controls to ensure that Federal Financial Reporting is performed, and review of reports submitted is documented. Additionally, as there have been recent revisions to the Uniform Grant Guidance (2 CFR 200) that now require documented internal controls over compliance, we also recommend that a specific policy be established for Federal Financial Reporting to give clear directives of how Federal Financial Reporting will be performed, documented, and retained ensuring there is current documentation of the internal controls over compliance. Management’s Response: Management concurs with the finding and will implement effective internal controls over Financial Reporting.

2025-002 Finding – Federal Awards – AL #14.267 – Continuum of Care Program Type: Significant Deficiency in Internal Control over Compliance – Special Tests: Rent Reasonableness Criteria / Requirement: 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition / Context: In testing Special Tests - Rental Reasonableness one out of four sample selected did not have a documented file review. The file appeared complete and there was no noncompliance noted, however there was no documented internal control over the rent reasonableness calculation. Cause: The process for file review was updated during the year to include a HUD file checklist not previously used. Three of the four files included the checklist which documents the review by the Housing Program Manager; however, one file was created before the checklist was in use. No other documentation of the review of the file was maintained, other than the associated check issued to the rental property company. Effect: Rental payments made on behalf of the Organization’s clients could be made for amounts above the HUD guideline’s maximum amount for the area, and therefore out of compliance with the federal award. Questioned Costs: None Recommendation: We recommend that the Organization continue with the internal controls established later in the year and ensure that Rent Reasonableness testing is documented including the file review. Additionally, as there have been recent revisions to the Uniform Grant Guidance (2 CFR 200) that now require documented internal controls over compliance, we also recommend that a specific policy be established for Rent Reasonableness to give clear directives of how the Organization determines rent reasonableness, how it is documented, and retained, ensuring there is current documentation of the internal controls over compliance. Management’s Response: Management concurs with the finding and has implement effective internal controls over Special Tests – Rent Reasonableness.

Type of Finding: Material Weakness in Internal Control over Compliance Federal Agency: United States Department of Health and Human Services Federal Program Name: Family Violence Prevention and Services/Discretionary Assistance Listing Number: 93.592 Federal Award Identification Number and Year: 90EV0467 Award Period for 90EV0467-02 and 90EV0467-03: September 30, 2020 through September 29, 2024 Award Period for 90EV0467-C6: March 15, 2021 through September 30, 2025 Criteria or specific requirement: CFR 200.318 states the non-Federal entity's documented procurement procedures must conform to the procurement standards identified in CFR sections 200.317 through 200.327. Condition: During our procurement testing, it was noted the procurement policy was written to comply with OMB Circular A-110 (2 CFR 215). As the requirements stated in the Circular have been superseded by OMB Uniform Guidance 2 CFR part 200, the policy as it is written is out of compliance. Questioned costs: None. Context: Though the current procurement policy was not updated to comply with 2 CFR Part 200 procurement standards the 3 samples selected during our audit did not identify instances of noncompliance with procurement standards. Cause: Management was not aware of the specific compliance requirement changes and thus, did not update its procurement policy. Effect: By not having an updated policy, the Organization could enter into a material transaction that is not compliant with 2 CFR Part 200. Repeat Finding: No. Recommendation: We recommend the client update its procurement policy so it is compliant with 2 CFR Part 200. Views of responsible officials: Management agrees with the finding and has provided its corrective action plan.

Finding # 2020-001 Type: Federal Award ? Material weakness CFDA Number: U.S. Department of Housing and Urban Development 14.267 Continuum of Care Requirement: Case files should be reviewed for proper documentation by supervisory personnel. Condition/Context: Out of a sample of 40 selected for testing, all case files were missing supervisory review. Procedures for reviewing assistance to recipients were not in place or carried out. Additionally, 5 out of 40 case files were missing the case manager signature on intake form denoting appropriate recipient. Cause: Case files are maintained in paper copies. Due to staffing changes and the impacts of COVID-19 case file reviews were not completed and paperwork was not printed and signed. Effect: Participants and costs could be ineligible for the program or case files could be missing required paperwork. Questioned Costs: Unknown Recommendation: Procedures should be put in place to ensure reviews are completed timely. This might include considering moving files to electronic format or further developing the process for monitoring to ensure all reviews are completed and documented. Management?s Response: Management will review and adjust the current file review policy and update it for working in a remote environment due to the impact of COVID-19 and ensure process carried out. Program leadership will also develop a system for documenting eligibility for placement by participants and incorporate this into the regular review system.

Finding # 2020-002 Type: Federal Award ? Material Weakness CFDA Number: U.S. Department of Housing and Urban Development 14.267 Continuum of Care Requirement: Invoices should be reviewed by supervisory personnel. Condition/Context: Invoices were prepared and submitted by the Finance Director with no independent review and approval. Cause: There is no control in place to review invoices. Effect: Invoices and reimbursements to the Organization may be inaccurate. Questioned Costs: None Recommendation: Supporting schedules should be reviewed with invoices by supervisory personnel. Management?s Response: Management has developed a process to send invoices from Finance Director to Executive Director for review prior to submission.

Finding # 2020-003 Type: Federal Award ? Significant deficiency, Noncompliance CFDA Number: U.S. Department of Housing and Urban Development 14.267 Continuum of Care Requirement: The Organization is required to ensure reasonable rents are paid on behalf of participants. Condition/Context: Two out of 40 rents tested for participants were above allowed amounts. Cause: The Organization was using incorrect rental rates for reasonableness analysis. Effect: Costs were allowed to be paid for rental locations above the allowed amounts. Questioned Costs: None Recommendation: We recommend the rent reasonableness summary be modified to include the approved HUD rates for each year. Management?s Response: Management has directed program leadership to use the approved HUD rates when determining reasonableness.