EIN: 760533828
UEI: FYSJSD8K5JJ5
Audited by: WHITLEY PENN LLP
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 13, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 13, 2027 (127 days from today).
What is a management decision? →FAC accepted this audit on July 9, 2025 — management decision was due January 9, 2026.
FAC accepted this audit on June 6, 2024 — management decision was due December 6, 2024.
FAC accepted this audit on July 17, 2023 — management decision was due January 17, 2024.
FAC accepted this audit on September 19, 2022 — management decision was due March 19, 2023.
Finding #2021-002 ? Significant Deficiency and Other Noncompliance ? Procurement Applicable federal program: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Rapid Rehousing Program Assistance Listing #14.267 Contract #?s: TX0569D6E001900, TX0569D6E002001, TX0429L6E001904, TX0429L6E002005, TX0538D6E001901, TX0538D6E002002, TX0539D6E001901 and TX0569D6E001900 Contract years: 10/01/20 ? 09/30/21, 10/01/20 ? 09/30/21, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, and 08/01/21 ? 07/31/22 Criteria: Procurement ? Procurement for federal expenditures must follow the requirements of Uniform Guidance ?200.318 and the Council?s procurement policies. Condition and context: The Council?s written procurement policy requires that competitive bids be obtained from multiple qualified vendors for purchases in excess of $25,000. Testing revealed that three of the four aggregate expenditures over $25,000 for the year ended December 31, 2021 had not been competitively procured. This is a repeat of finding #2020-004. Cause: The finding occurred as a result of the Council not following its procurement policy. Effect: Failure to follow its procurement policy and Uniform Guidance could result in the Council?s purchase of goods or services at a cost greater than the amount required if competitive procedure policies had been utilized. Questioned costs: Unknown Recommendation: Management should provide additional training on the procurement policy to staff with purchasing authority. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2021-002 ? Significant Deficiency and Other Noncompliance ? Procurement Applicable federal program: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Rapid Rehousing Program Assistance Listing #14.267 Contract #?s: TX0569D6E001900, TX0569D6E002001, TX0429L6E001904, TX0429L6E002005, TX0538D6E001901, TX0538D6E002002, TX0539D6E001901 and TX0569D6E001900 Contract years: 10/01/20 ? 09/30/21, 10/01/20 ? 09/30/21, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, and 08/01/21 ? 07/31/22 Criteria: Procurement ? Procurement for federal expenditures must follow the requirements of Uniform Guidance ?200.318 and the Council?s procurement policies. Condition and context: The Council?s written procurement policy requires that competitive bids be obtained from multiple qualified vendors for purchases in excess of $25,000. Testing revealed that three of the four aggregate expenditures over $25,000 for the year ended December 31, 2021 had not been competitively procured. This is a repeat of finding #2020-004. Cause: The finding occurred as a result of the Council not following its procurement policy. Effect: Failure to follow its procurement policy and Uniform Guidance could result in the Council?s purchase of goods or services at a cost greater than the amount required if competitive procedure policies had been utilized. Questioned costs: Unknown Recommendation: Management should provide additional training on the procurement policy to staff with purchasing authority. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2021-002 ? Significant Deficiency and Other Noncompliance ? Procurement Recommendation: Management should provide additional training on the procurement policy to staff with purchasing authority. Planned corrective action: The Council has delegated procurement to the Communications and Operations Director with the assistance of the Finance Director. This will be added to the Council?s policies and training will be provided for the leadership team related to procurement policies and procedures. Responsible officer: Executive Director and Finance Director Estimated completion date: October 1, 2022
2020-004
Finding #2021-003 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Rapid Rehousing Program Assistance Listing #14.267 Contract #?s: TX0569D6E001900, TX0569D6E002001, TX0429L6E001904, TX0429L6E002005, TX0538D6E001901, TX0538D6E002002, TX0539D6E001901 and TX0569D6E001900 Contract years: 10/01/20 ? 09/30/21, 10/01/20 ? 09/30/21, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, and 08/01/21 ? 07/31/22 Criteria: Subrecipient contracts ? Uniform Administrative Requirements, Subpart D-Post Federal Award Requirements, Subrecipient Monitoring and Management (Uniform Guidance Procurement Standards) ?200.332 requires every subaward to include certain information such as Assistance Listing number, FAIN number, name of federal awarding agency and award period of performance, including start and end dates. Condition and context: The Council?s two subrecipient award contracts under Assistance Listing #14.267 did not include the FAIN number and the subaward start and end dates. This is a repeat of finding #2020-005. Cause: The Council?s controls over issuance of subrecipient awards is not adequate to ensure that the contracts contain all required information. Effect: Lack of adequate information provided to subrecipients could result in the subrecipients not having information necessary to comply with federal compliance requirements. Recommendation: Policies and procedures should be implemented for review of contracts before issuance to ensure the contracts contain the required information. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2021-003 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Rapid Rehousing Program Assistance Listing #14.267 Contract #?s: TX0569D6E001900, TX0569D6E002001, TX0429L6E001904, TX0429L6E002005, TX0538D6E001901, TX0538D6E002002, TX0539D6E001901 and TX0569D6E001900 Contract years: 10/01/20 ? 09/30/21, 10/01/20 ? 09/30/21, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, and 08/01/21 ? 07/31/22 Criteria: Subrecipient contracts ? Uniform Administrative Requirements, Subpart D-Post Federal Award Requirements, Subrecipient Monitoring and Management (Uniform Guidance Procurement Standards) ?200.332 requires every subaward to include certain information such as Assistance Listing number, FAIN number, name of federal awarding agency and award period of performance, including start and end dates. Condition and context: The Council?s two subrecipient award contracts under Assistance Listing #14.267 did not include the FAIN number and the subaward start and end dates. This is a repeat of finding #2020-005. Cause: The Council?s controls over issuance of subrecipient awards is not adequate to ensure that the contracts contain all required information. Effect: Lack of adequate information provided to subrecipients could result in the subrecipients not having information necessary to comply with federal compliance requirements. Recommendation: Policies and procedures should be implemented for review of contracts before issuance to ensure the contracts contain the required information. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2021-003 ? Significant Deficiency and Other Noncompliance Recommendation: Policies and procedures should be implemented for review of contracts before issuance to ensure the contracts contain the required information. Planned corrective action: The Council will strengthen its review procedures related to contracts to ensure the contracts contain the required information. Responsible officer: Executive Director Estimated completion date: October 1, 2022
2020-005
Finding #2021-004 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Rapid Rehousing Program Assistance Listing #14.267 Contract #?s: TX0569D6E001900, TX0569D6E002001, TX0429L6E001904, TX0429L6E002005, TX0538D6E001901, TX0538D6E002002, TX0539D6E001901 and TX0569D6E001900 Contract years: 10/01/20 ? 09/30/21, 10/01/20 ? 09/30/21, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, and 08/01/21 ? 07/31/22 Criteria: Allowable Costs/Period of Performance ? Uniform Administrative Requirements, Subpart E-Cost Principles, Factors Affecting Allowability of Costs ?200.403 requires costs to be incurred during the approved budget period to be allowable. Condition and context: For 1 of 20 items tested for period of performance, the expenditure was incurred outside of the budget period. Cause: The Council?s controls over grants are not adequate to ensure that all costs charged to the grant are incurred within the appropriate budget period. Effect: Reporting of expenses incurred outside the approved budget period could result in disallowed costs. Questioned costs: $1,905 Recommendation: Policies and procedures should be implemented for review of expenses charged to grants to ensure they were incurred within the approved budget period. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2021-004 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Rapid Rehousing Program Assistance Listing #14.267 Contract #?s: TX0569D6E001900, TX0569D6E002001, TX0429L6E001904, TX0429L6E002005, TX0538D6E001901, TX0538D6E002002, TX0539D6E001901 and TX0569D6E001900 Contract years: 10/01/20 ? 09/30/21, 10/01/20 ? 09/30/21, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, 08/01/21 ? 07/31/22, 08/01/20 ? 07/31/21, and 08/01/21 ? 07/31/22 Criteria: Allowable Costs/Period of Performance ? Uniform Administrative Requirements, Subpart E-Cost Principles, Factors Affecting Allowability of Costs ?200.403 requires costs to be incurred during the approved budget period to be allowable. Condition and context: For 1 of 20 items tested for period of performance, the expenditure was incurred outside of the budget period. Cause: The Council?s controls over grants are not adequate to ensure that all costs charged to the grant are incurred within the appropriate budget period. Effect: Reporting of expenses incurred outside the approved budget period could result in disallowed costs. Questioned costs: $1,905 Recommendation: Policies and procedures should be implemented for review of expenses charged to grants to ensure they were incurred within the approved budget period. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2021-004 ? Significant Deficiency and Other Noncompliance Recommendation: Policies and procedures should be implemented for review of expenses charged to grants to ensure they were incurred within the approved budget period. Planned corrective action: Policies and procedures will be updated and revised to reflect that the Executive Director?s review of coding at time of approval includes a review of proper period. Additionally, a quarterly report will be provided to the Executive Director for her review of expenditures. Responsible officer: Finance Director Estimated completion date: October 1, 2022
FAC accepted this audit on November 10, 2021 — management decision was due May 10, 2022.
Finding #2020-003 ? Significant Deficiency ? Cash Disbursements Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #?s: TX0429L6E001803, TX0538D6E001800, TX0539D6E01800, TX0429L6E001904, TX0538D6E001901, TX0539D6E001901 and TX0569D6E001900 Contract years: 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21 and 10/01/20 ? 09/30/21 U. S. Department of Treasury Passed through Harris County: Coronavirus Relief Fund Assistance Listing #21.019 Contract #: SLT0119 Contract year: 04/01/20 ? 03/31/21 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division: Crime Victim Assistance Assistance Listing #16.575 Contract #?s: 2855503, 3308302, 2855504 and 3308303 Contract years: 10/01/18 ? 09/30/20, 10/01/18 ? 09/30/20, 10/01/20 ? 09/30/21 and 10/01/20 ? 09/30/21 U. S. Department of Justice Passed through Texas Office of Governor, Criminal Justice Division: Violence Against Women Formula Grants Assistance Listing #16.588 Contract #?s: 2654007 and 2654008 Contract years: 09/01/19 ? 08/31/20 and 09/01/20 ? 08/31/21 U. S. Department of Treasury Passed through Harris County: Coronavirus Relief Fund Assistance Listing #21.019 Contract #: SLT0119 Contract year: 04/01/20 ? 03/31/21 The significant deficiency reported as finding #2020-002 applies to all federal programs. This is a partial repeat of finding #2019-005. Questioned costs: None Recommendation: See finding #2020-002. Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2020-003 ? Significant Deficiency ? Cash Disbursements Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #?s: TX0429L6E001803, TX0538D6E001800, TX0539D6E01800, TX0429L6E001904, TX0538D6E001901, TX0539D6E001901 and TX0569D6E001900 Contract years: 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21 and 10/01/20 ? 09/30/21 U. S. Department of Treasury Passed through Harris County: Coronavirus Relief Fund Assistance Listing #21.019 Contract #: SLT0119 Contract year: 04/01/20 ? 03/31/21 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division: Crime Victim Assistance Assistance Listing #16.575 Contract #?s: 2855503, 3308302, 2855504 and 3308303 Contract years: 10/01/18 ? 09/30/20, 10/01/18 ? 09/30/20, 10/01/20 ? 09/30/21 and 10/01/20 ? 09/30/21 U. S. Department of Justice Passed through Texas Office of Governor, Criminal Justice Division: Violence Against Women Formula Grants Assistance Listing #16.588 Contract #?s: 2654007 and 2654008 Contract years: 09/01/19 ? 08/31/20 and 09/01/20 ? 08/31/21 U. S. Department of Treasury Passed through Harris County: Coronavirus Relief Fund Assistance Listing #21.019 Contract #: SLT0119 Contract year: 04/01/20 ? 03/31/21 The significant deficiency reported as finding #2020-002 applies to all federal programs. This is a partial repeat of finding #2019-005. Questioned costs: None Recommendation: See finding #2020-002. Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Finding #2020-003 ? Significant Deficiency ? Cash Disbursements Recommendation: See finding #2020-002. Planned corrective action: The Council will remove the Executive Director from the Administrator role within QuickBooks and will have read-only access effective October 31, 2021. Responsible officer: Finance Director Estimated completion date: October 31, 2021
2019-005
Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #?s: TX0429L6E001803, TX0538D6E001800, TX0539D6E01800, TX0429L6E001904, TX0538D6E001901, TX0539D6E001901 and TX0569D6E001900 Contract years: 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21 and 10/01/20 ? 09/30/21 Criteria: Procurement ? Procurement for federal expenditures must follow the requirements of Uniform Guidance ?200.318 and the Council?s procurement policies. Condition and context: The Council?s written procurement policy requires that competitive bids be obtained from multiple qualified vendors for purchases in excess of $25,000. Testing revealed that one of the two aggregate expenditures over $25,000 for the year ended December 31, 2020 had not been competitively procured. This is a repeat of finding #2019-006. Cause: The finding occurred as a result of the Council not following its procurement policy. Effect: Failure to follow its procurement policy and Uniform Guidance could result in the Council?s purchase of goods or services at a cost greater than the amount required if competitive procedure policies had been utilized. Questioned costs: Unknown Recommendation: Management should provide additional training on the procurement policy to staff with purchasing authority. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #?s: TX0429L6E001803, TX0538D6E001800, TX0539D6E01800, TX0429L6E001904, TX0538D6E001901, TX0539D6E001901 and TX0569D6E001900 Contract years: 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21 and 10/01/20 ? 09/30/21 Criteria: Procurement ? Procurement for federal expenditures must follow the requirements of Uniform Guidance ?200.318 and the Council?s procurement policies. Condition and context: The Council?s written procurement policy requires that competitive bids be obtained from multiple qualified vendors for purchases in excess of $25,000. Testing revealed that one of the two aggregate expenditures over $25,000 for the year ended December 31, 2020 had not been competitively procured. This is a repeat of finding #2019-006. Cause: The finding occurred as a result of the Council not following its procurement policy. Effect: Failure to follow its procurement policy and Uniform Guidance could result in the Council?s purchase of goods or services at a cost greater than the amount required if competitive procedure policies had been utilized. Questioned costs: Unknown Recommendation: Management should provide additional training on the procurement policy to staff with purchasing authority. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2020-004 ? Significant Deficiency and Other Noncompliance ? Procurement Recommendation: Management should provide additional training on the procurement policy to staff with purchasing authority. Planned corrective action: The Council has retrained all staff on purchasing authority and the procurement policy. Responsible officer: Executive Director and Finance Director Estimated completion date: Completed
2019-006
Finding #2020-005 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #?s: TX0429L6E001803, TX0538D6E001800, TX0539D6E01800, TX0429L6E001904, TX0538D6E001901, TX0539D6E001901 and TX0569D6E001900 Contract years: 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21 and 10/01/20 ? 09/30/21 U. S. Department of Treasury Passed through Harris County: Coronavirus Relief Fund Assistance Listing #21.019 Contract #: SLT0119 Contract year: 04/01/20 ? 03/31/21 Criteria: Sub-recipient contracts ? Uniform Administrative Requirements, Subpart D-Post Federal Award Requirements, Sub-recipient Monitoring and Management (Uniform Guidance Procurement Standards) ?200.331 requires every subaward to include certain information such as Assistance Listing number, FAIN number, name of federal awarding agency and award period of performance, including start and end dates. Condition and context: The Council?s two sub-recipient award contracts under Assistance Listing #14.267 did not include the FAIN number and the subaward start and end dates. We also reviewed three of fourteen sub-recipient award contracts under Assistance Listing #21.019 and found all three were missing the Assistance Listing number, FAIN number, and name of federal awarding agency. This is a repeat of finding #2019-009. Cause: The Council?s controls over issuance of sub-recipient awards is not adequate to ensure that the contracts contain all required information. Effect: Lack of adequate information provided to subrecipients could result in the subrecipients not having information necessary to comply with federal compliance requirements. Questioned costs: Unknown Recommendation: Policies and procedures should be implemented for review of contracts before issuance to make ensure the contracts contain the required information. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2020-005 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #?s: TX0429L6E001803, TX0538D6E001800, TX0539D6E01800, TX0429L6E001904, TX0538D6E001901, TX0539D6E001901 and TX0569D6E001900 Contract years: 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/19 ? 07/31/20, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21, 08/01/20 ? 07/31/21 and 10/01/20 ? 09/30/21 U. S. Department of Treasury Passed through Harris County: Coronavirus Relief Fund Assistance Listing #21.019 Contract #: SLT0119 Contract year: 04/01/20 ? 03/31/21 Criteria: Sub-recipient contracts ? Uniform Administrative Requirements, Subpart D-Post Federal Award Requirements, Sub-recipient Monitoring and Management (Uniform Guidance Procurement Standards) ?200.331 requires every subaward to include certain information such as Assistance Listing number, FAIN number, name of federal awarding agency and award period of performance, including start and end dates. Condition and context: The Council?s two sub-recipient award contracts under Assistance Listing #14.267 did not include the FAIN number and the subaward start and end dates. We also reviewed three of fourteen sub-recipient award contracts under Assistance Listing #21.019 and found all three were missing the Assistance Listing number, FAIN number, and name of federal awarding agency. This is a repeat of finding #2019-009. Cause: The Council?s controls over issuance of sub-recipient awards is not adequate to ensure that the contracts contain all required information. Effect: Lack of adequate information provided to subrecipients could result in the subrecipients not having information necessary to comply with federal compliance requirements. Questioned costs: Unknown Recommendation: Policies and procedures should be implemented for review of contracts before issuance to make ensure the contracts contain the required information. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2020-005 ? Significant Deficiency and Other Noncompliance Recommendation: Policies and procedures should be implemented for review of contracts before issuance to make ensure the contracts contain the required information. Planned corrective action: The Council will revise policies and procedures and retrain staff related to contracts to ensure required information is contained within each contract. Responsible officer: Executive Director Estimated completion date: October 31, 2021
2019-009
FAC accepted this audit on December 17, 2020 — management decision was due June 17, 2021.
Finding #2019-004 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 9/30/20 and 10/01/18 ? 09/30/20 Criteria: Reporting ? Management of the Council is responsible for establishing and maintaining an effective system of internal control over government grant reporting to ensure all costs are reported in the correct period and that government grant revenue and receivables are properly reflected in the financial statements in accordance with generally accepted accounting principles. Condition and context: The finding reported as #2019-001 reported HUD program adjustments of approximately $52,000 to record program expenditures in the correct fiscal year. Cause and effect: As a result of not having effective internal control procedures over accruals, revenues and expenses were understated. Questioned costs: None Recommendation: See Finding 2019-001 Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2019-004 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 9/30/20 and 10/01/18 ? 09/30/20 Criteria: Reporting ? Management of the Council is responsible for establishing and maintaining an effective system of internal control over government grant reporting to ensure all costs are reported in the correct period and that government grant revenue and receivables are properly reflected in the financial statements in accordance with generally accepted accounting principles. Condition and context: The finding reported as #2019-001 reported HUD program adjustments of approximately $52,000 to record program expenditures in the correct fiscal year. Cause and effect: As a result of not having effective internal control procedures over accruals, revenues and expenses were understated. Questioned costs: None Recommendation: See Finding 2019-001 Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Finding #2019-004 ? Significant Deficiency and Other Noncompliance Condition and context: The finding reported as #2019-001 reported HUD program adjustments of approximately $52,000 to record program expenditures in the correct fiscal year. Recommendation: See Finding 2019-001 Planned corrective action: The Finance Director is now aware of the proper method for reporting government grant revenue and receivables in the financial statements. This has been corrected. Responsible officer: Finance Director Estimated completion date: Completed
Finding #2019-005 ? Significant Deficiency Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 9/30/20 and 10/01/18 ? 09/30/20 U. S. Department of Justice Passed through Texas Office of Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.588 Contract #s ? 2654006 and 2654007 Contract years: 09/01/18 ? 08/30/19 and 09/01/19 ? 08/30/20 The significant deficiency reported as finding #2019-003 applies to all federal programs. Questioned costs: Unknown Recommendation: See Finding 2019-003 Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2019-005 ? Significant Deficiency Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 9/30/20 and 10/01/18 ? 09/30/20 U. S. Department of Justice Passed through Texas Office of Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.588 Contract #s ? 2654006 and 2654007 Contract years: 09/01/18 ? 08/30/19 and 09/01/19 ? 08/30/20 The significant deficiency reported as finding #2019-003 applies to all federal programs. Questioned costs: Unknown Recommendation: See Finding 2019-003 Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Finding #2019-005 ? Significant Deficiency The significant deficiency reported as finding #2019-003 applies to all federal programs. Recommendation: See Finding 2019-003 Planned corrective action: As a small administrative staff exists for the organization and there are only two signers for the checks, this creates a burden when one person is unavailable. A third signer has been added to the account and the policy will be revised for requiring two signers to address checks that are over the amount of $25,000. Check stock is locked and not available to the Finance Director without the Executive Director?s approval. The Office Manager will log inventory of check stock for the organization tracking the check numbers of checks provided to the Finance Director. The Executive Director will have read-only capability for the general ledger and will receive a copy of the check log. Responsible officer: Executive Director and Finance Director Estimated completion date: December 30, 2020
Finding #2019-006 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 9/30/20 and 10/01/18 ? 09/30/20 Criteria: Procurement ? Procurement for federal expenditures must follow the requirements of the Uniform Guidance ?200.318 and the Council?s procurement policies. Condition and context: The Council?s written procurement policy requires that competitive bids be obtained from multiple qualified vendors for purchases in excess of $5,000. Testing revealed that two of the three aggregate expenditures over that threshold had no documentation of competitive procurement. Cause: The finding occurred as a result of the Council not following their procurement policy. Effect: Failure to follow their procurement policy and Uniform Guidance could result in the Council?s purchase of goods or services at a cost greater than the amount required if competitive procedure policies had been utilized. Questioned costs: Unknown Recommendation: Management should provide additional training on the procurement policy to staff with purchasing authority. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2019-006 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 9/30/20 and 10/01/18 ? 09/30/20 Criteria: Procurement ? Procurement for federal expenditures must follow the requirements of the Uniform Guidance ?200.318 and the Council?s procurement policies. Condition and context: The Council?s written procurement policy requires that competitive bids be obtained from multiple qualified vendors for purchases in excess of $5,000. Testing revealed that two of the three aggregate expenditures over that threshold had no documentation of competitive procurement. Cause: The finding occurred as a result of the Council not following their procurement policy. Effect: Failure to follow their procurement policy and Uniform Guidance could result in the Council?s purchase of goods or services at a cost greater than the amount required if competitive procedure policies had been utilized. Questioned costs: Unknown Recommendation: Management should provide additional training on the procurement policy to staff with purchasing authority. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2019-006 ? Significant Deficiency and Other Noncompliance Condition and context: The Council?s written procurement policy requires that competitive bids be obtained from multiple qualified vendors for purchases in excess of $5,000. Testing revealed that two of the three aggregate expenditures over that threshold had no documentation of competitive procurement. Recommendation: Management should provide additional training on the procurement policy.to staff with purchasing authority. Planned corrective action: Management will revise its written procurement policy to ensure that required procurement procedures are not overly burdensome while also achieving compliance with required federal regulations. Responsible officer: Executive Director and Board of Directors Estimated completion date: December 30, 2020
Finding #2019-007 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 09/30/20 and 10/01/18 ? 09/30/20 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages, be based on records that accurately reflect the work performed. These records must 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. The Council?s procedures for allocating costs are not sufficient to ensure that costs are appropriately allocated amongst federal funding streams. Condition and context: The Council utilizes timesheets to record time and effort based on actual time expended. A sample of 21 payroll disbursements, including all employees charged to the grant, revealed 3 instances of one employee?s time charged to the grant in excess of the time indicated on the timesheet. Cause: The Council requests salary reimbursement based on management?s allocation of available funding rather than based on the actual time spent on the grant. Effect: Examination of all charges for the one employee revealed approximately $4,300 charged to the grant in excess of the amount indicated on the timesheets allocated to be charged to the grant. However, for the 3 timesheets tested, the timesheets reflect that 100% of the employee?s time was spent on the program and thus, could be charged to the grant. Questioned costs: $4,364 Recommendation: Re-emphasize procedures for ensuring that salaries and related costs charged to federal programs are supported by personnel reports of actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2019-007 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 09/30/20 and 10/01/18 ? 09/30/20 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages, be based on records that accurately reflect the work performed. These records must 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. The Council?s procedures for allocating costs are not sufficient to ensure that costs are appropriately allocated amongst federal funding streams. Condition and context: The Council utilizes timesheets to record time and effort based on actual time expended. A sample of 21 payroll disbursements, including all employees charged to the grant, revealed 3 instances of one employee?s time charged to the grant in excess of the time indicated on the timesheet. Cause: The Council requests salary reimbursement based on management?s allocation of available funding rather than based on the actual time spent on the grant. Effect: Examination of all charges for the one employee revealed approximately $4,300 charged to the grant in excess of the amount indicated on the timesheets allocated to be charged to the grant. However, for the 3 timesheets tested, the timesheets reflect that 100% of the employee?s time was spent on the program and thus, could be charged to the grant. Questioned costs: $4,364 Recommendation: Re-emphasize procedures for ensuring that salaries and related costs charged to federal programs are supported by personnel reports of actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2019-007 ? Significant Deficiency and Other Noncompliance Condition and context: The Council utilizes timesheets to record time and effort based on actual time expended. A sample of 21 payroll disbursements, including all employees charged to the grant, revealed 3 instances of one employee?s time charged to the grant in excess of the time indicated on the timesheet. Recommendation: Re-emphasize procedures for ensuring that salaries and related costs charged to federal programs are supported by personnel reports of actual time worked. Planned corrective action: All timesheets currently reflect the activities of each employee. Any amount charged to the grants and current grants reimbursements are accurate. The Finance Director ensures that costs charged are accurate and the Grants Compliance will ensure that all timesheets correctly account for activities of each staff. Responsible officer: Executive Director and Finance Director Estimated completion date: November 20, 2020
Finding #2019-008 ? Significant Deficiency Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 9/30/20 and 10/01/18 ? 09/30/20 Criteria: Internal control ? Management is responsible for establishing and maintaining an effective system of internal control over government grant billings to ensure all costs are reimbursed and that government grant revenue and receivables are properly reflected in the financial statements in accordance with generally accepted accounting principles in the United States. Condition and context: We selected 9 reimbursement requests to test for evidence of approval and supporting detail of expenditures; none of the requests have evidence of independent approval. Cause and effect: The Finance Director and Executive Director review the requests together but did not retain supporting evidence of the review. Failure to establish and maintain an adequate internal control system over government grant billings could result in the Council not being reimbursed for program costs or overbilling government grants. Questioned costs: Unknown Recommendation: Policies and procedures should be implemented to retain documentation of independent review and approval. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2019-008 ? Significant Deficiency Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 9/30/20 and 10/01/18 ? 09/30/20 Criteria: Internal control ? Management is responsible for establishing and maintaining an effective system of internal control over government grant billings to ensure all costs are reimbursed and that government grant revenue and receivables are properly reflected in the financial statements in accordance with generally accepted accounting principles in the United States. Condition and context: We selected 9 reimbursement requests to test for evidence of approval and supporting detail of expenditures; none of the requests have evidence of independent approval. Cause and effect: The Finance Director and Executive Director review the requests together but did not retain supporting evidence of the review. Failure to establish and maintain an adequate internal control system over government grant billings could result in the Council not being reimbursed for program costs or overbilling government grants. Questioned costs: Unknown Recommendation: Policies and procedures should be implemented to retain documentation of independent review and approval. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2019-008 ? Significant Deficiency Condition and context: We selected 9 reimbursement requests to test for evidence of approval and supporting detail of expenditures; none of the requests have evidence of independent approval. Recommendation: Policies and procedures should be implemented to retain documentation of independent review and approval. Planned corrective action: All reimbursement requests have supporting documentation and expense requests are signed off by supervisors using a reimbursement request form. All procedures are in place. Responsible officer: Executive Director Estimated completion date: Completed
Finding #2019-009 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 Criteria: Sub-recipient contracts ? The Uniform Administrative Requirements, Subpart D-Post Federal Award Requirements, Sub-recipient Monitoring and Management (Uniform Guidance Procurement Standards) ?200.331 requires every subaward include certain information such as CFDA number and award period of performance. Condition and context: We reviewed three sub-recipient awards for required information. Two out of three were missing the CFDA number and all three were missing the period of performance. Cause: The Council?s controls over issuance of sub-recipient awards is not adequate to ensure that the contracts contain all required information. Effect: Lack of adequate information provided to subrecipients could result in the subrecipients not having information necessary for complying with federal compliance requirements. Questioned costs: Unknown Recommendation: Policies and procedures should be implemented for review of contracts before issuance to make ensure the contracts contain required information. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2019-009 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Housing and Urban Development Continuum of Care Program, Rapid Rehousing Program CFDA #14.267 Contract #s ? TX0476L6E001701, TX0429L6E001702, TX0538D6E001800 and TX0429L6E001803 Contract years: 08/01/18 ? 07/31/19, 12/01/18 ? 11/30/19, 08/01/19 ? 07/31/20 and 08/01/19 ? 07/31/20 Criteria: Sub-recipient contracts ? The Uniform Administrative Requirements, Subpart D-Post Federal Award Requirements, Sub-recipient Monitoring and Management (Uniform Guidance Procurement Standards) ?200.331 requires every subaward include certain information such as CFDA number and award period of performance. Condition and context: We reviewed three sub-recipient awards for required information. Two out of three were missing the CFDA number and all three were missing the period of performance. Cause: The Council?s controls over issuance of sub-recipient awards is not adequate to ensure that the contracts contain all required information. Effect: Lack of adequate information provided to subrecipients could result in the subrecipients not having information necessary for complying with federal compliance requirements. Questioned costs: Unknown Recommendation: Policies and procedures should be implemented for review of contracts before issuance to make ensure the contracts contain required information. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2019-009 ? Significant Deficiency and Other Noncompliance Condition and context: We reviewed three sub-recipient awards for required information. Two out of three were missing the CFDA number and all three were missing the period of performance. Recommendation: Policies and procedures should be implemented for review of contracts before issuance to make ensure the contracts contain required information. Planned corrective action: Policies include that contracts will have the required information and the Executive Director and Finance Director will develop a template to ensure that all contracts have the required information. Finance Director will review and approve all contracts prior to being released. Responsible officer: Finance Director Estimated completion date: November 20, 2020
Finding #2019-010 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 09/30/ 20 and 10/01/18 ? 09/30/20 Criteria: Special provisions ? The contract requires that each non-profit receiving funds obtain and have on file a blanket fidelity bond that indemnifies the Criminal Justice Department against the loss or theft of the entire amount of grant funds for the grant period. Condition and context: The Council has not purchased a fidelity bond. Cause and effect: Management has not complied with the grant requirement for fidelity bond coverages. As a result, theft losses could occur and not be insured. Questioned costs: Unknown Recommendation: Purchase a fidelity bond to provide the coverage required by the grant award. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2019-010 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Justice Passed through Texas Office of the Governor, Criminal Justice Division Crime Victim Assistance CFDA #16.575 Contract #s ? 2855503 and 3308302 Contract years: 10/01/18 ? 09/30/ 20 and 10/01/18 ? 09/30/20 Criteria: Special provisions ? The contract requires that each non-profit receiving funds obtain and have on file a blanket fidelity bond that indemnifies the Criminal Justice Department against the loss or theft of the entire amount of grant funds for the grant period. Condition and context: The Council has not purchased a fidelity bond. Cause and effect: Management has not complied with the grant requirement for fidelity bond coverages. As a result, theft losses could occur and not be insured. Questioned costs: Unknown Recommendation: Purchase a fidelity bond to provide the coverage required by the grant award. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2019-010 ? Significant Deficiency and Other Noncompliance Condition and context: The Council has not purchased a fidelity bond. Recommendation: Purchase a fidelity bond to provide the coverage required by the grant award. Planned corrective action: A fidelity bond has been purchased. Responsible officer: Executive Director Estimated completion date: Completed October 12, 2020
FAC accepted this audit on October 13, 2019 — management decision was due April 13, 2020.
FAC accepted this audit on October 8, 2018 — management decision was due April 8, 2019.
GSA_MIGRATION
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GSA_MIGRATION
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