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THE SALVATION ARMY - NORTH TEXAS AREA COMMAND - OPERATING FUNDNon-Profit

EIN: 580660607

UEI: PEN1W464K158

Audited by: BKHM, P.A.

Oversight agency: 14 [Department of Housing and Urban Development]

View federal awards & risk assessment →

Data as of September 7, 2026

THE SALVATION ARMY - NORTH TEXAS AREA COMMAND - OPERATING FUND148 audit years9 findings4 repeat
148
Audit Years
9
Total Findings
4
Repeat Findings
$7.6M
Federal Awards Expended (FY 2025)
FY 2025-09-30FY 2025-09-30FY 2025-09-30FY 2025-09-30FY 2025-09-30FY 2025-09-30FY 2025-09-30FY 2025-09-30FY 2025-09-30FY 2025-09-30FY 2025-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2024-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2023-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2022-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2021-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2020-09-30FY 2019-09-30FY 2019-09-30FY 2019-09-30FY 2019-09-30FY 2019-09-30FY 2019-09-30FY 2019-09-30FY 2019-09-30FY 2019-09-30FY 2019-09-30FY 2019-09-30FY 2018-09-30FY 2018-09-30FY 2018-09-30FY 2018-09-30FY 2018-09-30FY 2018-09-30FY 2018-09-30FY 2018-09-30FY 2018-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2017-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30FY 2016-09-30

FY 2025-09-30

LOW-RISK AUDITEE$7,550,112 federal awards expended
2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

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Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

$2,190,829 federal awards expended

FAC accepted this audit on June 5, 2026 — management decision was due December 5, 2026.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Show full finding ▾
Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

$2,521,371 federal awards expended

FAC accepted this audit on April 16, 2026 — management decision was due October 16, 2026.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

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Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

LOW-RISK AUDITEE$1,424,387 federal awards expended

FAC accepted this audit on May 5, 2026 — management decision was due November 5, 2026.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Show full finding ▾
Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

$8,098,813 federal awards expended

FAC accepted this audit on May 5, 2026 — management decision was due November 5, 2026.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Show full finding ▾
Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

LOW-RISK AUDITEE$1,212,782 federal awards expended

FAC accepted this audit on April 30, 2026 — management decision was due October 30, 2026.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

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Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

LOW-RISK AUDITEE$1,102,732 federal awards expended

FAC accepted this audit on May 13, 2026 — management decision was due November 13, 2026.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

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Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

LOW-RISK AUDITEE$1,502,825 federal awards expended

FAC accepted this audit on June 1, 2026 — management decision was due December 1, 2026.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

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Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

$1,212,148 federal awards expended

FAC accepted this audit on June 22, 2026 — management decision was due December 22, 2026.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

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Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

LOW-RISK AUDITEE$1,678,606 federal awards expended

FAC accepted this audit on July 21, 2026 — management decision was due January 21, 2027.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

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Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2025-09-30

LOW-RISK AUDITEE$1,803,711 federal awards expended

FAC accepted this audit on September 3, 2026 — management decision was due March 3, 2027.

2025-002
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

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Full finding narrative

Finding 2025-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Over Compliance and Compliance Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. There are also several instances of no record keeping for certain payroll runs and individuals. Questioned Costs: The Organization switched payroll companies during the year and was unable to provide 5 out of 8 payroll details related to what was allocated to the VA Homeless Providers Grant and Per Diem Program (“VOM”) program which represented $118,085 of payroll expenditures allocated to the program. Out of the 3 payroll registers (15 employees) we were able to test, 2 PAR reports did not match the allocation charged to the grant, and 5 PAR reports were missing which represented $724 of payroll expenditures allocated to the program. Context: This condition occurred on certain employees. We tested 3 payroll period and a total of 15 employees, of which 7 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employees charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs.   Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →

FY 2024-09-30

$1,220,083 federal awards expended

FAC accepted this audit on May 29, 2025 — management decision was due November 29, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Full finding narrative

Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

$3,712,531 federal awards expended

FAC accepted this audit on June 4, 2025 — management decision was due December 4, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

LOW-RISK AUDITEE$1,103,736 federal awards expended

FAC accepted this audit on June 13, 2025 — management decision was due December 13, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Full finding narrative

Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

LOW-RISK AUDITEE$1,228,103 federal awards expended

FAC accepted this audit on April 28, 2025 — management decision was due October 28, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Full finding narrative

Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

LOW-RISK AUDITEE$9,449,967 federal awards expended

FAC accepted this audit on June 13, 2025 — management decision was due December 13, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Full finding narrative

Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

$7,551,619 federal awards expended

FAC accepted this audit on March 25, 2025 — management decision was due September 25, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Full finding narrative

Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

LOW-RISK AUDITEE$1,062,828 federal awards expended

FAC accepted this audit on April 9, 2025 — management decision was due October 9, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Full finding narrative

Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

LOW-RISK AUDITEE$1,597,651 federal awards expended

FAC accepted this audit on April 15, 2025 — management decision was due October 15, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Full finding narrative

Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

$1,030,116 federal awards expended

FAC accepted this audit on December 8, 2025 — management decision was due June 8, 2026.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Full finding narrative

Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

$4,893,675 federal awards expended

FAC accepted this audit on April 23, 2025 — management decision was due October 23, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

$752,842 federal awards expended

FAC accepted this audit on August 4, 2025 — management decision was due February 4, 2026.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

LOW-RISK AUDITEE$964,503 federal awards expended

FAC accepted this audit on May 10, 2025 — management decision was due November 10, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

$1,440,801 federal awards expended

FAC accepted this audit on August 18, 2025 — management decision was due February 18, 2026.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

$2,938,603 federal awards expended

FAC accepted this audit on June 27, 2025 — management decision was due December 27, 2025.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

$2,712,825 federal awards expended

FAC accepted this audit on November 12, 2025 — management decision was due May 12, 2026.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2024-09-30

$855,745 federal awards expended

FAC accepted this audit on February 18, 2026 — management decision was due August 18, 2026.

2024-002
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003QUESTIONED COSTS

The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

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Full finding narrative

Finding 2024-002 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Type of Finding: Significant deficiency Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates.   Condition: The Organization is charging payroll costs to the grant and the general ledger through predetermined percentage as entered into the payroll system rather than the actual time spent on the grant through the personal action report (“PAR”) as signed by the employee and supervisor. Questioned Costs: 8 out of 24 payroll period had $19,994 more charged to the grant vs. the signed personal action report. Context: This condition occurred on certain employees. We tested 8 payroll period and a total of 33 employees of which 13 had exceptions. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants, but the actual time worked on the grant is not updated in the payroll system. Effect: Inaccurate payroll costs may be charged to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award. Management’s Response: See Corrective Action Plan

Corrective Action Plan

Effective March 2025, the staff at Red Shield is required to conduct a time study, twice per year. The findings from the study are used to determine percentages of labor hours/pay to be assigned to each program. Any changes are to be immediately relayed to Human Resources and updated in the payroll system.

Prior Finding References

2023-003

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$2,628,405 federal awards expended

FAC accepted this audit on April 25, 2024 — management decision was due October 25, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$944,720 federal awards expended

FAC accepted this audit on February 9, 2024 — management decision was due August 9, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

$1,257,215 federal awards expended

FAC accepted this audit on April 26, 2024 — management decision was due October 26, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

$4,369,085 federal awards expended

FAC accepted this audit on April 9, 2024 — management decision was due October 9, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

$2,123,956 federal awards expended

FAC accepted this audit on August 29, 2024 — management decision was due March 1, 2025.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$1,449,361 federal awards expended

FAC accepted this audit on May 22, 2024 — management decision was due November 22, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Full finding narrative

Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$1,053,285 federal awards expended

FAC accepted this audit on May 6, 2024 — management decision was due November 6, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Full finding narrative

Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$1,599,419 federal awards expended

FAC accepted this audit on June 24, 2024 — management decision was due December 24, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Full finding narrative

Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$2,347,680 federal awards expended

FAC accepted this audit on June 6, 2024 — management decision was due December 6, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$2,472,724 federal awards expended

FAC accepted this audit on June 20, 2024 — management decision was due December 20, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Full finding narrative

Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$11,755,189 federal awards expended

FAC accepted this audit on June 28, 2024 — management decision was due December 28, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Full finding narrative

Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$2,993,004 federal awards expended

FAC accepted this audit on June 28, 2024 — management decision was due December 28, 2024.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

LOW-RISK AUDITEE$8,249,679 federal awards expended

FAC accepted this audit on July 1, 2024 — management decision was due January 1, 2025.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

$884,335 federal awards expended

FAC accepted this audit on July 12, 2024 — management decision was due January 12, 2025.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

$1,195,475 federal awards expended

FAC accepted this audit on November 21, 2024 — management decision was due May 21, 2025.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

$1,241,018 federal awards expended

FAC accepted this audit on February 1, 2025 — management decision was due August 1, 2025.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2023-09-30

$953,101 federal awards expended

FAC accepted this audit on February 19, 2025 — management decision was due August 19, 2025.

2023-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001OTHER MATTERS

The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2023-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year-end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2023, will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2024. Cause of Condition: While the audit was completed in advance of the due date, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner due to the lengthy review process of the Organization to provide approval of the audit report. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2022 as finding number 2022-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command understands and accepts the recommendation and will work with the audit firm to ensure that the future audits will be completed and filed timely.

Prior Finding References

2022-001

About Reporting →
2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

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Finding 2023-002- Allowable Costs/Activities Allowed Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Funds spent under the grant must be allowed under Title 2 U.S. Code of Federal Regulations Part 200 Subpart E, Cost Principles (“Cost Principles”). Condition: During the course of the auditing procedures we noted that The Operating Fund did not have expenditures to support the total amount drawn down under the grant. Questioned costs: $37,883 Context: Of the $906,065 drawn down under the grant, the Organization only had detail and supporting accounting records to support qualifying expenses of $770,585. Prior to year-end, the Operating fund became aware that amounts were being overdrawn and opted to not submit reimbursement requests for expenses incurred in September of 2023, leaving a remaining overdrawn amount as of September 30, 2023 of $37,883. Effect: The excess amounts drawn down could be deemed to be unallowable and have to be returned to the grantor. Cause: Due to an ineffective review process of the costs charged to the grant compared to the total recognized as revenue and reported as expenditures. Recommendation: Management should ensure all cost expenditures are properly documented and supported before being charged to the grant. Any funds received more than actual federal expenditures should be recorded as a refundable advance. Grantee Comment: Refer to Corrective Action Plan

Corrective Action Plan

Financial records were submitted to and reviewed by the Veteran’s Administration. Instructions were received from the VA, regarding repayment of the overpayment in FY2023. Reimbursement has been made to the Veteran’s Administration, in accordance with the due date and instructions received from the Veteran’s Administration. Further, a revised per diem rate request has been submitted to and approved by the Veteran’s Administration, reducing the per diem rate to more accurately reflect current expenditures. Red Shield has recently filled a critical grants compliance position, which allows proper staffing for reviewing monthly financial reports, to ensure all allowable costs are being captured, and adjusting per diem rates, as needed. Red Shield VOM staff, MAAC grants staff, and MAAC finance staff have begun monthly meetings to review the current financial status of the VOM program, in relation to invoiced grant income and recorded expenditures.

About Activities Allowed or Unallowed →
2023-003
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

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Full finding narrative

Finding 2023-003 - Allowable Costs/Cost Principles (Allocation of Payroll) Funding Agency: U.S. Department of Veterans Affairs Direct Funding Grant: Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the nonfederal entity and(iii) Reasonably reflect the total activity for which the employee is compensated by the nonfederal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The nonfederal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. Condition: The Organization is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: Unknown Context: This condition occurred in all payroll transactions selected for testing, and based on inquiries with program administrators, regular review of these allocations was not being performed consistently throughout the year. Cause: The Organization has a tracking system in place to monitor the wages by employee charged to federal grants to avoid over-allocation of individual employee wages per the grant budget, but this tracking system does not contain a process for identifying and allocating wages based on submitted time records or actual time spent on various programs. Effect: Inaccurate payroll costs may be charged to federal programs if the Organization does not have procedures in place to monitor and record employee time devoted to federal programs. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants are supported by a system of internal controls which provides reasonable assurance that the charges are accurate allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee works on more than one federal award.

Corrective Action Plan

The Executive Director over the VOM program has reviewed the allocation percentages for all employees working with the Veteran’s program. The adjusted percentages have been submitted to the payroll department and updated in Ceridian, accordingly. Further, the staff at Red Shield has determined a streamlined calculation process for allocation of payroll between VOM and other government programs, which will be used going forward. The director of Red Shield, along with his grants compliance team will review the allocation percentages for payroll related to all programs/grants at a minimum of once per quarter, to ensure that information in Ceridian matches true staffing allocations and is properly recorded in the financial record.

About Activities Allowed or Unallowed →

FY 2022-09-30

$1,410,662 federal awards expended

FAC accepted this audit on November 16, 2023 — management decision was due May 16, 2024.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$2,837,176 federal awards expended

FAC accepted this audit on February 26, 2023 — management decision was due August 26, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$10,004,832 federal awards expended

FAC accepted this audit on July 1, 2023 — management decision was due January 1, 2024.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$844,437 federal awards expended

FAC accepted this audit on February 26, 2023 — management decision was due August 26, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Show full finding ▾
Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$803,799 federal awards expended

FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$1,262,711 federal awards expended

FAC accepted this audit on June 22, 2023 — management decision was due December 22, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Show full finding ▾
Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$1,717,400 federal awards expended

FAC accepted this audit on June 28, 2023 — management decision was due December 28, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Show full finding ▾
Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$5,216,542 federal awards expended

FAC accepted this audit on April 26, 2023 — management decision was due October 26, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Show full finding ▾
Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$1,328,603 federal awards expended

FAC accepted this audit on January 23, 2023 — management decision was due July 23, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$1,446,464 federal awards expended

FAC accepted this audit on March 19, 2023 — management decision was due September 19, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Show full finding ▾
Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$966,184 federal awards expended

FAC accepted this audit on August 14, 2023 — management decision was due February 14, 2024.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$13,700,956 federal awards expended

FAC accepted this audit on May 16, 2023 — management decision was due November 16, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$811,691 federal awards expended

FAC accepted this audit on April 5, 2023 — management decision was due October 5, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$801,138 federal awards expended

FAC accepted this audit on June 15, 2023 — management decision was due December 15, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$1,388,171 federal awards expended

FAC accepted this audit on March 27, 2023 — management decision was due September 27, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Show full finding ▾
Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$3,004,110 federal awards expended

FAC accepted this audit on March 8, 2023 — management decision was due September 8, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Show full finding ▾
Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$8,025,647 federal awards expended

FAC accepted this audit on May 9, 2023 — management decision was due November 9, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Show full finding ▾
Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$1,170,365 federal awards expended

FAC accepted this audit on September 6, 2023 — management decision was due March 6, 2024.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Show full finding ▾
Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$1,264,757 federal awards expended

FAC accepted this audit on August 9, 2023 — management decision was due February 9, 2024.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$2,820,547 federal awards expended

FAC accepted this audit on June 28, 2023 — management decision was due December 28, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

GOING CONCERN$2,163,174 federal awards expended

FAC accepted this audit on April 19, 2023 — management decision was due October 19, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

LOW-RISK AUDITEE$1,035,111 federal awards expended

FAC accepted this audit on March 26, 2023 — management decision was due September 26, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2022-09-30

$1,028,885 federal awards expended

FAC accepted this audit on March 17, 2026 — management decision was due September 17, 2026.

2022-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001

The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

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Full finding narrative

Finding No. 2022-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2022 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2023. Cause of Condition: Due to the late completion of the September 30, 2022 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Identification of Repeat Finding: The finding is a repeat of a finding noted in the audit for September 30, 2021 as finding number 2021-001. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan.

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN August 16, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2021 through September 30, 2022 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section II of the schedule, Financial Statement Findings, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2022-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2023 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

Prior Finding References

2021-001

About Reporting →

FY 2021-09-30

$7,194,397 federal awards expended

FAC accepted this audit on July 20, 2022 — management decision was due January 20, 2023.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

$1,191,643 federal awards expended

FAC accepted this audit on May 25, 2023 — management decision was due November 25, 2023.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$2,070,261 federal awards expended

FAC accepted this audit on April 24, 2022 — management decision was due October 24, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

$1,097,911 federal awards expended

FAC accepted this audit on July 20, 2022 — management decision was due January 20, 2023.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

$959,417 federal awards expended

FAC accepted this audit on March 21, 2022 — management decision was due September 21, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

$1,136,096 federal awards expended

FAC accepted this audit on March 7, 2023 — management decision was due September 7, 2023.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

$865,554 federal awards expended

FAC accepted this audit on June 16, 2022 — management decision was due December 16, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$1,733,881 federal awards expended

FAC accepted this audit on November 20, 2022 — management decision was due May 20, 2023.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$12,281,586 federal awards expended

FAC accepted this audit on June 28, 2022 — management decision was due December 28, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

$1,358,154 federal awards expended

FAC accepted this audit on May 1, 2022 — management decision was due November 1, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$2,933,690 federal awards expended

FAC accepted this audit on June 28, 2022 — management decision was due December 28, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$3,455,157 federal awards expended

FAC accepted this audit on June 21, 2022 — management decision was due December 21, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

$1,131,863 federal awards expended

FAC accepted this audit on April 5, 2022 — management decision was due October 5, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$1,233,957 federal awards expended

FAC accepted this audit on March 14, 2022 — management decision was due September 14, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$1,369,639 federal awards expended

FAC accepted this audit on April 18, 2022 — management decision was due October 18, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$2,272,704 federal awards expended

FAC accepted this audit on March 29, 2022 — management decision was due September 29, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$7,702,244 federal awards expended

FAC accepted this audit on April 12, 2022 — management decision was due October 12, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

$6,648,520 federal awards expended

FAC accepted this audit on June 16, 2022 — management decision was due December 16, 2022.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

LOW-RISK AUDITEE$1,282,978 federal awards expended

FAC accepted this audit on February 21, 2023 — management decision was due August 21, 2023.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2021-09-30

$1,328,603 federal awards expended

FAC accepted this audit on February 17, 2023 — management decision was due August 17, 2023.

2021-001
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

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Full finding narrative

ALLOWABLE COSTS/COST PRINCIPLES-Material Weakness in Compliance and Internal Control over Compliance. CRITERIA: Title V-Banking, Subtitle A-Emergency Rental Assistance, Section 501(c)(5)(A) states that not more than 10% (ERA-1) / 15% (ERA-2) of the amount paid to an eligible grantee may be used for administrative costs attributable to providing financial assistance and housing stability services. This percentage is further limited by the proposal submitted by the Company and approved by the pass-through grantor. CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis. Limited staff and limited time for thorough study of all agency regulations and guidelines. EFFECT: Management spent approximately $1,016,812 on administrative costs. Of these administrative costs, only $172,876 qualified as eligible administrative fees pursuant to the terms of the contracts, the Company?s proposals, and federal guidelines. QUESTIONED COSTS:$843,936. PERSPECTIVE: It was noted during discussions with the client that the passthrough entity initially approved administrative cost that were later disallowed, as summarized in EFFECT. REPEAT FINDING: No. RECOMMENDATION: We recommend that Divisional Headquarters continue to manage the grant application process, with particular attention to new program requirements at all levels of funding and pass-through funding, and assign a resource to communicate requirements to local commands with ongoing oversight to ensure program implementation in compliance with grantor standards and that any unclear grant contract provisions or requirements be agreed upon in written communication from a responsible party of the grantor. MANAGEMENT RESPONSE: Management agrees with the finding and has repaid all disallowed expenditures. CORRECTIVE ACTION PLAN: See management?s corrective action plan for details.

Corrective Action Plan

CONDITION: Excess and unapproved funds were spent on administrative costs. CAUSE: Rapid deployment of a new federal program during a global humanitarian crisis where initial allowable cost guidance provided by the pass-through-grantor required additional clarification subsequent to the grantee?s initial reimbursement requests. This clarification disallowed reimbursement for expenses initially believed to be allowable by the grantee under the contract. MANAGEMENT RESPONSE: Management agrees with the finding. When notified that amounts that were originally reimbursed by the grantor were not eligible for reimbursement, the grantee expeditiously repaid these expenditures to the grantor. CORRECTIVE ACTION PLAN: Going forward, all contracts will be reviewed in detail and any provisions that require additional clarification will require clarification in writing, approved by grantor personnel with the appropriate authority to make such decisions. Management at Divisional Headquarters will continue to review and approve grant applications and will assign resources to provide guidance and oversight of local implementation. COMPLETION DATE: May 24, 2022.

About Allowable Costs / Cost Principles →
2021-001
Reporting
SIGNIFICANT DEFICIENCY

The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

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Full finding narrative

Finding No. 2021-001: Significant Deficiency: Criteria: The Organization is required to file the Uniform Guidance Audit with the Federal Clearinghouse within nine months of the year end of the Organization. Statement of Condition: The Uniform Guidance Audit for September 30, 2021 will be completed and submitted to the Federal Clearinghouse after the due date of June 30, 2022. Cause of Condition: Due to the late completion of the September 30, 2021 audit, the audit was unable to be submitted to the Federal Clearinghouse in a timely manner. Effect of Condition: The effect is that the compliance requirement to file timely with the Federal Clearinghouse was not met. Recommendation: The Organization should have future audits completed timely and filed timely with the Federal Clearinghouse. Views of Responsible Officials: Management understands and accepts the recommendation as outlined in the Corrective Action Plan

Corrective Action Plan

THE SALVATION ARMY, LOUISVILLE AREA COMMAND CORRECTIVE ACTION PLAN April 25, 2023 U.S. Department of Housing and Urban Development The Salvation Army, Louisville Area Command respectfully submits the following corrective action plan for the year ended September 30, 2021. Name and address of independent public accounting firm: Deming, Malone, Livesay & Ostroff, PSC, 9300 Shelbyville Road, Suite 1100, Louisville, Kentucky 40222. Audit period: October 1, 2020 through September 30, 2021 The finding from the September 30, 2021 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section I of the schedule, Summary of Auditors? Results and Section III of the schedule, Federal Award Findings and Questioned Costs, do not include findings and are not addressed. Findings ? Federal Award Finding No. 2021-001: Recommendation: The Salvation Army, Louisville Area Command should have future audits completed timely and filed timely with the Federal Clearinghouse. Action Taken: The Salvation Army, Louisville Area Command has engaged an audit firm to conduct the audits of years ending September 30, 2022 and forward with the understanding that the future audits will be completed and filed timely. If there are questions regarding this plan, please call Patricia Juliot at 502-671-4928.

About Reporting →
2021-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

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Full finding narrative

Criteria or specific requirement: The Area Command is responsible for ensuring that grant disbursements are to be spent in accordance with the grant agreement and documentation for grant charges are properly maintained. ? Condition: During the audit, 42 grant disbursements were selected for testing, one exception was noted that $16,320 of expenditures were requested for reimbursement twice. Consequently, the $1,238 of the indirect cost associated with it is also unallowable. Additionally, $653 of expenditures requested for reimbursement is missing appropriate supporting documents. ? Effect: The Area Command had costs charged to the grant that were unallowable and the documentation for grant charges are not properly maintained.? Cause: The Area Command did not have proper controls in place to ensure allowable costs were charged to the grant and to ensure documentation for grant charges are properly maintained. ? Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. ? Views of responsible officials and planned corrective actions: Management agrees with the finding.

Corrective Action Plan

Recommendation: The Area Command management should implement controls and procedures to ensure compliance with the grant requirement. Views of responsible officials and planned corrective actions: Management agrees with the finding. A two-month window of pandemic response brought finance department beyond capacity. The Management has begun the process of strengthening the program review procedures to ensure that only allowable expenditures are charged to the grants and all supporting documents for the charges are properly maintained.

About Allowable Costs / Cost Principles →

FY 2020-09-30

LOW-RISK AUDITEE$1,491,916 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 27, 2021 — management decision was due December 27, 2021.

FY 2020-09-30

$839,798 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 24, 2021 — management decision was due December 24, 2021.

FY 2020-09-30

$764,406 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 19, 2021 — management decision was due October 19, 2021.

FY 2020-09-30

$1,981,332 federal awards expendedNo findings recorded this year

FAC accepted this audit on December 15, 2021 — management decision was due June 15, 2022.

FY 2020-09-30

QUALIFIED OPINIONLOW-RISK AUDITEE$839,898 federal awards expendedNo findings recorded this year

FAC accepted this audit on December 22, 2021 — management decision was due June 22, 2022.

FY 2020-09-30

$768,397 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 12, 2021 — management decision was due January 12, 2022.

FY 2020-09-30

$843,495 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 28, 2021 — management decision was due July 28, 2021.

FY 2020-09-30

$940,127 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 28, 2021 — management decision was due December 28, 2021.

FY 2020-09-30

LOW-RISK AUDITEE$1,707,813 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 28, 2021 — management decision was due September 28, 2021.

FY 2020-09-30

LOW-RISK AUDITEE$4,682,455 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 17, 2021 — management decision was due November 17, 2021.

FY 2020-09-30

LOW-RISK AUDITEE$1,011,986 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 18, 2021 — management decision was due October 18, 2021.

FY 2020-09-30

LOW-RISK AUDITEE$847,145 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 8, 2021 — management decision was due May 8, 2022.

FY 2020-09-30

LOW-RISK AUDITEE$1,795,252 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 29, 2021 — management decision was due December 29, 2021.

FY 2020-09-30

LOW-RISK AUDITEE$826,971 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 15, 2021 — management decision was due August 15, 2021.

FY 2020-09-30

LOW-RISK AUDITEE$5,176,687 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 18, 2021 — management decision was due October 18, 2021.

FY 2019-09-30

$853,124 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 23, 2020 — management decision was due July 23, 2020.

FY 2019-09-30

LOW-RISK AUDITEE$3,429,564 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 12, 2020 — management decision was due November 12, 2020.

FY 2019-09-30

LOW-RISK AUDITEE$968,062 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 11, 2020 — management decision was due September 11, 2020.

FY 2019-09-30

$852,166 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 18, 2020 — management decision was due November 18, 2020.

FY 2019-09-30

LOW-RISK AUDITEE$1,524,566 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 11, 2020 — management decision was due December 11, 2020.

FY 2019-09-30

$833,097 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 16, 2020 — management decision was due October 16, 2020.

FY 2019-09-30

LOW-RISK AUDITEE$1,550,223 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 20, 2020 — management decision was due October 20, 2020.

FY 2019-09-30

LOW-RISK AUDITEE$4,430,721 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 1, 2020 — management decision was due October 1, 2020.

FY 2019-09-30

$858,221 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 18, 2020 — management decision was due December 18, 2020.

FY 2019-09-30

LOW-RISK AUDITEE$1,233,766 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 18, 2020 — management decision was due September 18, 2020.

FY 2019-09-30

LOW-RISK AUDITEE$1,024,585 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 1, 2020 — management decision was due December 1, 2020.

FY 2018-09-30

$786,350 federal awards expendedNo findings recorded this year

FAC accepted this audit on October 13, 2019 — management decision was due April 13, 2020.

FY 2018-09-30

LOW-RISK AUDITEE$1,115,218 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 24, 2019 — management decision was due December 24, 2019.

FY 2018-09-30

$4,156,752 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 18, 2019 — management decision was due October 18, 2019.

FY 2018-09-30

LOW-RISK AUDITEE$1,508,124 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 11, 2019 — management decision was due October 11, 2019.

FY 2018-09-30

LOW-RISK AUDITEE$1,559,392 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 17, 2019 — management decision was due October 17, 2019.

FY 2018-09-30

LOW-RISK AUDITEE$5,026,997 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 24, 2019 — management decision was due October 24, 2019.

FY 2018-09-30

$880,689 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 17, 2019 — management decision was due October 17, 2019.

FY 2018-09-30

LOW-RISK AUDITEE$924,301 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 10, 2019 — management decision was due August 10, 2019.

FY 2018-09-30

LOW-RISK AUDITEE$1,318,317 federal awards expendedNo findings recorded this year

FAC accepted this audit on September 5, 2019 — management decision was due March 5, 2020.

FY 2017-09-30

LOW-RISK AUDITEE$782,786 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 19, 2018 — management decision was due October 19, 2018.

FY 2017-09-30

LOW-RISK AUDITEE$1,395,807 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 7, 2018 — management decision was due December 7, 2018.

FY 2017-09-30

$860,554 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 17, 2018 — management decision was due January 17, 2019.

FY 2017-09-30

$3,471,176 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 4, 2018 — management decision was due October 4, 2018.

FY 2017-09-30

LOW-RISK AUDITEE$965,413 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 1, 2018 — management decision was due August 1, 2018.

FY 2017-09-30

LOW-RISK AUDITEE$1,145,338 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 3, 2018 — management decision was due November 3, 2018.

FY 2017-09-30

LOW-RISK AUDITEE$1,245,218 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 27, 2018 — management decision was due December 27, 2018.

FY 2017-09-30

LOW-RISK AUDITEE$1,727,249 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 9, 2018 — management decision was due October 9, 2018.

FY 2017-09-30

$2,052,578 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 23, 2018 — management decision was due January 23, 2019.

FY 2017-09-30

LOW-RISK AUDITEE$4,541,105 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.

FY 2017-09-30

LOW-RISK AUDITEE$1,480,890 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 22, 2018 — management decision was due November 22, 2018.

FY 2017-09-30

LOW-RISK AUDITEE$1,726,373 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 26, 2018 — management decision was due December 26, 2018.

FY 2016-09-30

LOW-RISK AUDITEE$2,357,963 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 8, 2017 — management decision was due December 8, 2017.

FY 2016-09-30

$994,497 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 15, 2017 — management decision was due November 15, 2017.

FY 2016-09-30

LOW-RISK AUDITEE$1,685,478 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 27, 2017 — management decision was due October 27, 2017.

FY 2016-09-30

LOW-RISK AUDITEE$3,062,707 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 4, 2017 — management decision was due November 4, 2017.

FY 2016-09-30

$2,217,593 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 16, 2017 — management decision was due May 16, 2018.

FY 2016-09-30

$801,058 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 16, 2017 — management decision was due January 16, 2018.

FY 2016-09-30

LOW-RISK AUDITEE$4,062,050 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 2, 2017 — management decision was due November 2, 2017.

FY 2016-09-30

LOW-RISK AUDITEE$982,603 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 31, 2017 — management decision was due December 1, 2017.

FY 2016-09-30

LOW-RISK AUDITEE$786,222 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 1, 2017 — management decision was due November 1, 2017.

FY 2016-09-30

LOW-RISK AUDITEE$1,360,425 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 18, 2017 — management decision was due November 18, 2017.

FY 2016-09-30

LOW-RISK AUDITEE$1,276,552 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 28, 2017 — management decision was due December 28, 2017.

FY 2016-09-30

LOW-RISK AUDITEE$977,608 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 10, 2017 — management decision was due January 10, 2018.

FY 2016-09-30

LOW-RISK AUDITEE$896,409 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 16, 2017 — management decision was due August 16, 2017.

FY 2016-09-30

LOW-RISK AUDITEE$1,603,458 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 19, 2017 — management decision was due December 19, 2017.

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