EIN: 850370709
UEI: HK2GWVHRKD93
Audited by: Waters and Company, LLC
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 August 5, 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 February 5, 2027 (150 days from today).
What is a management decision? →FAC accepted this audit on July 28, 2026 — management decision was due January 28, 2027.
FAC accepted this audit on September 12, 2024 — management decision was due March 12, 2025.
Statement of Condition During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed to meet the federal requirements. VSS’s capital asset records were incomplete and had not been reconciled with the physical inventory conducted by each department. Additionally, the auditor proposed material adjustments to record capital assets that had been improperly expensed. Also, VSS does not have an annual certified inventory list, signed by the management. Context The issues below were noted for both programs tested: • During our testwork we noted no physical inventory was taken during the fiscal year ended June 30, 2023. • The fixed asset listing does not contain the required information to properly identify purchases with federal funds. • VSS does not currently tag all assets purchased with federal monies. • VSS does not have controls in place to track purchases with federal funds on a spreadsheet or something similar.
Show full finding ▾Hide full finding ▴Statement of Condition During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed to meet the federal requirements. VSS’s capital asset records were incomplete and had not been reconciled with the physical inventory conducted by each department. Additionally, the auditor proposed material adjustments to record capital assets that had been improperly expensed. Also, VSS does not have an annual certified inventory list, signed by the management. Context The issues below were noted for both programs tested: • During our testwork we noted no physical inventory was taken during the fiscal year ended June 30, 2023. • The fixed asset listing does not contain the required information to properly identify purchases with federal funds. • VSS does not currently tag all assets purchased with federal monies. • VSS does not have controls in place to track purchases with federal funds on a spreadsheet or something similar.
VSS will add additional information into the inventory list so that it meets federal requirements. The inventory list will be maintained during the fiscal year and an internal audit will be conducted at the end of the fiscal year to ensure all equipment is accounted for.
2022-002
Condition During our testing, we noted VSS’s internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals.
Show full finding ▾Hide full finding ▴Condition During our testing, we noted VSS’s internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals.
VSS has already updated its financial policies to include electronic approval of expenditures through Bill.com. Bill.com was established for accounts payables mid FY 2024-FY 2025 for credit card payments. VSS has added Bill.com Accounts Payable and credit card services to include approvals required per grant and department.
2022-004
Statement of Condition During our testing, we noted VSS did not comply with the period of performance requirements.
Show full finding ▾Hide full finding ▴Statement of Condition During our testing, we noted VSS did not comply with the period of performance requirements.
VSS has hired and is onboarding and participating with YPTC with a timeline of the remainder of the current fiscal year (FY24) and the beginning of next fiscal year (FY25). YPTC’s scope of work will include evaluating, updating, and training on new finance policies and procedures to include but not limited to reviewing period of performance requirements.
2022-005
Statement of Condition During our testing, we noted that VSS internal controls surrounding fair market rent did not comply with the program requirements. Specifically, in our examination of the special provision for fair market rent, we noted that VSS’s assessment of the fair market rent for one unit was based on higher square footage than the apartment which was actually rented. Additionally, we noted that for two units, the certification was not completed properly. Finally, the rent for one unit was higher than the documented applicable Payment Standard without an explanation.
Show full finding ▾Hide full finding ▴Statement of Condition During our testing, we noted that VSS internal controls surrounding fair market rent did not comply with the program requirements. Specifically, in our examination of the special provision for fair market rent, we noted that VSS’s assessment of the fair market rent for one unit was based on higher square footage than the apartment which was actually rented. Additionally, we noted that for two units, the certification was not completed properly. Finally, the rent for one unit was higher than the documented applicable Payment Standard without an explanation.
The partnership between VSS and YPTC will serve to comprehensively evaluate current policies and procedures and ensure a best-practice, audit-compliant system of posting and review. Fair Market Rents (FMR) will be reviewed along with the HQS worksheet and income limits during annual recertification for active participants in the HUD program. VSS will review the HQS worksheet and income limits during annual recertification for active participants in the HUD program.
2022-006
Statement of Condition VSS has yet to submit the Data Collection Form as required by Uniform Guidance. The form is due no more than 9 months after the close of the fiscal year under audit.
Show full finding ▾Hide full finding ▴Statement of Condition VSS has yet to submit the Data Collection Form as required by Uniform Guidance. The form is due no more than 9 months after the close of the fiscal year under audit.
VSS has hired and is onboarding and participating with YPTC with a timeline of the remainder of the current fiscal year (FY24) and the beginning of next fiscal year (FY25). YPTC’s scope of work will include working with VSS’ staff, evaluating current policies and procedures, ensuring the implementation of best-practices systems of posting, year-end close, and review of standard practices and programing to evaluate, update, and train, on new finance policies and procedures. This partnership with YPTC will ensure future annual independent financial audits will be conducted on a timely basis and meet the nine-month filing requirements.
FAC accepted this audit on April 15, 2025 — management decision was due October 15, 2025.
During testwork over accrued payroll accounts, CLA noted the year-end adjustments made for accrued payroll and accrued vacation were erroneously calculated. Criteria or specific requirement: Under generally accepted accounting principles, expenses should be accrued the period in which they relate (hours worked in the case of accrued payroll and related liabilities). Effect: Understatement and overstatement of expenses and related liabilities. Cause: The year-end entry was not reviewed for accuracy, resulting in accrued payroll being understated and accrued vacation being overstated. Repeat Finding: See prior year finding 2020-001. Recommendation: CLA recommends management review the accrual entries in detail to ensure accuracy prior to recording. Views of responsible officials and planned corrective actions: VSS agrees with CLA in creating internal controls over reviewing year end entries. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Federal Program Title(s): ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria or specific requirement: Per §200.313, Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal Award Identification Number (FAIN)), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed to meet the federal requirements. Questioned costs: None. While VSS was not in compliance with the requirement for tracking and monitoring the federally procured equipment, there were no unallowed costs on equipment purchases made using federal funds. The material noncompliance relates to the context below, as there are no controls in place to ensure compliance with tracking and monitoring requirements. Context: The below issues were noted for both programs tested: During our testwork we noted no physical inventory was taken during the fiscal year ended June 30, 2022. The fixed asset listing does not contain the required information to properly identify purchases with federal funds. VSS does not currently tag assets purchased with federal monies. As such, due to the limited information present on invoices, we were not able to physically inspect all assets. -VSS does not have controls in place to track purchases with federal funds on a spreadsheet or similar. Of the 3 assets tested during 2022, none of the listed asset purchases complied with federal requirements. Cause: Lack of established controls and procedures over allowable costs principals, federal requirements for purchases using federal funds, and tracking of purchases made with federal funds. Effect: Possible noncompliance with federal cost principals and monitoring of assets purchased using federal funds. Repeat Finding: 2021-002 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: VSS agrees with CLA and has updated our policies over equipment tracking and purchasing in FY 2023. We have created a tracking system and installed asset tags on all equipment over our capitalization amount. A physical inventory will be conducted at the end of the fiscal year to ensure equipment is accounted for and in use.
Show full finding ▾Hide full finding ▴Type of Finding: Significant Deficiency in Internal Control over Financial Reporting Condition: During testwork over accrued payroll accounts, CLA noted the year-end adjustments made for accrued payroll and accrued vacation were erroneously calculated. Criteria or specific requirement: Under generally accepted accounting principles, expenses should be accrued the period in which they relate (hours worked in the case of accrued payroll and related liabilities). Effect: Understatement and overstatement of expenses and related liabilities. Cause: The year-end entry was not reviewed for accuracy, resulting in accrued payroll being understated and accrued vacation being overstated. Repeat Finding: See prior year finding 2020-001. Recommendation: CLA recommends management review the accrual entries in detail to ensure accuracy prior to recording. Views of responsible officials and planned corrective actions: VSS agrees with CLA in creating internal controls over reviewing year end entries. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Federal Program Title(s): ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria or specific requirement: Per §200.313, Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal Award Identification Number (FAIN)), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed to meet the federal requirements. Questioned costs: None. While VSS was not in compliance with the requirement for tracking and monitoring the federally procured equipment, there were no unallowed costs on equipment purchases made using federal funds. The material noncompliance relates to the context below, as there are no controls in place to ensure compliance with tracking and monitoring requirements. Context: The below issues were noted for both programs tested: During our testwork we noted no physical inventory was taken during the fiscal year ended June 30, 2022. The fixed asset listing does not contain the required information to properly identify purchases with federal funds. VSS does not currently tag assets purchased with federal monies. As such, due to the limited information present on invoices, we were not able to physically inspect all assets. -VSS does not have controls in place to track purchases with federal funds on a spreadsheet or similar. Of the 3 assets tested during 2022, none of the listed asset purchases complied with federal requirements. Cause: Lack of established controls and procedures over allowable costs principals, federal requirements for purchases using federal funds, and tracking of purchases made with federal funds. Effect: Possible noncompliance with federal cost principals and monitoring of assets purchased using federal funds. Repeat Finding: 2021-002 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: VSS agrees with CLA and has updated our policies over equipment tracking and purchasing in FY 2023. We have created a tracking system and installed asset tags on all equipment over our capitalization amount. A physical inventory will be conducted at the end of the fiscal year to ensure equipment is accounted for and in use.
Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS agrees with CLA and has updated our policies over equipment tracking and purchasing in FY 2023. We have created a tracking system and installed asset tags on all equipment over our capitalization amount. A physical inventory will be conducted at the end of the fiscal year to ensure equipment is accounted for and in use. Name(s) of the contact person(s) responsible for corrective action: Jessica Franco, Director of Finance Planned completion date for corrective action plan: 10/1/2022 for policy updates, 07/1/2022 was the date the accounts payable approval process took place.
2021-002
During our testing, we noted that VSS internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Repeat Finding: 2021-003 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. These are currently pending approval by the Board of Directors for implementation.
Show full finding ▾Hide full finding ▴Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. VSS should have internal controls designed to ensure compliance with this provision. 2 CFR 200.318-200.321 outline requirements maintain records sufficient to detail the history of procurement, requirements for competition, methods and purchasing thresholds, as well as other requirements for contracting with organizations with using federal funds. VSS’s policies do not meet these requirements. Condition: During our testing, we noted that VSS internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Repeat Finding: 2021-003 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. These are currently pending approval by the Board of Directors for implementation.
Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. These are currently pending approval by the Board of Directors for implementation. Name(s) of the contact person(s) responsible for corrective action: Jessica Franco, Director of Finance Planned completion date for corrective action plan: 10/1/2022
2021-003
During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals. Questioned costs: $51.60 (14.267) Context: 14.267 - during our testwork over allowable costs principals we noted 12 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Noted 1 of the 60 tested transactions did not have sufficient documentation to substantiate allowable activity under the grant. 16.575 - during our testwork over allowable costs principals we noted 21 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Cause: Lack of established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Repeat Finding: 2021-004 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Views of responsible officials: VSS agrees with CLA and has updated our financial policies to include electronic approval of expenditures through Bill.com. Timesheets and supplements will be reviewed and approved by staff supervisors biweekly to ensure proper allocation of hours worked. Credit Card Expense reports will require Description of item purchased, as well as the funder and class allocation.
Show full finding ▾Hide full finding ▴Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals. Questioned costs: $51.60 (14.267) Context: 14.267 - during our testwork over allowable costs principals we noted 12 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Noted 1 of the 60 tested transactions did not have sufficient documentation to substantiate allowable activity under the grant. 16.575 - during our testwork over allowable costs principals we noted 21 of the 60 tested transactions did not have sufficient documentation of approval of allowability. Cause: Lack of established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Repeat Finding: 2021-004 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Views of responsible officials: VSS agrees with CLA and has updated our financial policies to include electronic approval of expenditures through Bill.com. Timesheets and supplements will be reviewed and approved by staff supervisors biweekly to ensure proper allocation of hours worked. Credit Card Expense reports will require Description of item purchased, as well as the funder and class allocation.
Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS agrees with CLA and has updated our financial policies to include electronic approval of expenditures through Bill.com. Timesheets and supplements will be reviewed and approved by staff supervisors biweekly to ensure proper allocation of hours worked. Credit Card Expense reports will require Description of item purchased, as well as the funder and class allocation. Name(s) of the contact person(s) responsible for corrective action: Jessica Franco, Director of Finance Planned completion date for corrective action plan: 3/1/2023
2021-004
During our testing, we noted VSS did not comply with the period of performance requirements. Context and Questioned Costs: During our testwork over period of performance we noted the following: (14.267) We noted that 8 of the 35 tested transactions were partially outside the period of performance. Total Questioned Costs of $4,851. (16.575) We noted that 6 of the 14 tested transactions were partially outside the period of performance. Total Questioned Costs of $74. Cause: Lack of established controls and procedures over period of performance requirements. Effect: Possible noncompliance with federal requirements and charging costs to unavailable funds outside the period of performance. Repeat Finding: 2021-005 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: VSS agrees with CLA in creating internal controls over reviewing year end entries. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review.
Show full finding ▾Hide full finding ▴Federal Program Title(s): ALN 14.267 – Continuum of Care Program ALN 16.575 - Crime Victim Assistance Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Department of Justice (ALN 16.575) Pass-Through Agencies: New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) 2021-VA-979 (10/1/2020-9/30/2021) (16.575) 2022-VA-180 (10/1/2021-9/30/2022) (16.575) Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per §200.309 Period of Performance, a non-federal entity may charge to the Federal Award only allowable costs incurred during the period of performance. Condition: During our testing, we noted VSS did not comply with the period of performance requirements. Context and Questioned Costs: During our testwork over period of performance we noted the following: (14.267) We noted that 8 of the 35 tested transactions were partially outside the period of performance. Total Questioned Costs of $4,851. (16.575) We noted that 6 of the 14 tested transactions were partially outside the period of performance. Total Questioned Costs of $74. Cause: Lack of established controls and procedures over period of performance requirements. Effect: Possible noncompliance with federal requirements and charging costs to unavailable funds outside the period of performance. Repeat Finding: 2021-005 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: VSS agrees with CLA in creating internal controls over reviewing year end entries. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review.
Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS agrees with CLA in creating internal controls over reviewing year end entries. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Name(s) of the contact person(s) responsible for corrective action: Jessica Franco, Director of Finance Planned completion date for corrective action plan: 10/1/2022
2021-005
During our testing, we noted that VSS internal controls surrounding fair market rent did not comply with the program requirements. Context and Questioned Costs: During our testing over the special provision for fair market rent, we noted that VSS did not have an updated fair market calculation for 1 of the 5 tested participants. Additionally, noted that the number in the household decreased and there was not an assessment of the fair market rent allowable for the household size. Cause: Lack of established controls and procedures over the program’s fair market rent requirements. Effect: Possible noncompliance with federal requirements and HUD program requirements. Repeat Finding: N/A – New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal and grantor requirements regarding the program requirements. Views of responsible officials: VSS agrees with CLA and has updated our financial policies. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Fair Market Rents will be reviewed along with the HQS worksheet and Income Limits during annual recertification for active participants in the HUD program.
Show full finding ▾Hide full finding ▴Federal Program Title(s): ALN 14.267 – Continuum of Care Program Federal Agencies: Department of Housing and Urban Development (ALN 14.267) Pass-Through Agencies: N/A Award Numbers and Periods: NM0056L6B012001 (7/1/2021-6/30/2022) (14.267) NM0129D6B011901 (11/1/2020-10/31/2021) (14.267) NM0129D6B012002 (11/1/2021-10/31/2022) (14.267) Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 24 CFR 578.49(b)(1) - When grants are used to pay rent for all or part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent paid may not exceed rents currently being charged by the same owner for comparable unassisted space. Per 24 CFR 578.49(b)(1) - When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents. Condition: During our testing, we noted that VSS internal controls surrounding fair market rent did not comply with the program requirements. Context and Questioned Costs: During our testing over the special provision for fair market rent, we noted that VSS did not have an updated fair market calculation for 1 of the 5 tested participants. Additionally, noted that the number in the household decreased and there was not an assessment of the fair market rent allowable for the household size. Cause: Lack of established controls and procedures over the program’s fair market rent requirements. Effect: Possible noncompliance with federal requirements and HUD program requirements. Repeat Finding: N/A – New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal and grantor requirements regarding the program requirements. Views of responsible officials: VSS agrees with CLA and has updated our financial policies. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Fair Market Rents will be reviewed along with the HQS worksheet and Income Limits during annual recertification for active participants in the HUD program.
Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal and grantor requirements regarding the program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS agrees with CLA and has updated our financial policies. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Fair Market Rents will be reviewed along with the HQS worksheet and Income Limits during annual recertification for active participants in the HUD program. Name(s) of the contact person(s) responsible for corrective action: Jessica Franco, Director of Finance Planned completion date for corrective action plan: XXX
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed to meet the federal requirements. Questioned costs: None. While VSS was not in compliance with the requirement for tracking and monitoring the federally procured equipment, there were no unallowed costs on equipment purchases made using federal funds. The material noncompliance relates to the context below, as there are no controls in place to ensure compliance with tracking and monitoring requirements. Context: The below issues were noted for both programs tested: ? During our testwork we noted no physical inventory was taken during the fiscal year ended June 30, 2021. ? The fixed asset listing does not contain the required information to properly identify purchases with federal funds. ? VSS does not currently tag assets purchased with federal monies. As such, due to the limited information present on invoices, we were not able to physically inspect all assets. ? -VSS does not have controls in place to track purchases with federal funds on a spreadsheet or similar. o (14.231) 1 of the 1 assets tested did not comply with federal requirements. o (16.575) 5 of the 5 assets tested did not comply with federal requirements. Cause: Lack of established controls and procedures over allowable costs principals, federal requirements for purchases using federal funds, and tracking of purchases made with federal funds. Effect: Possible noncompliance with federal cost principals and monitoring of assets purchased using federal funds. Repeat Finding: N/A ? New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. During this period, VSS was transitioning from remote work to back to the office due to COVID-19. Currently, we are back in the office and have started physical inventory. This includes taking of a physical inventory annually, any assets that were procured with federal funds in FY21 or in future years will be identified as such in the fixed asset listing, any assets that VSS has identified that have been previously acquired using federal funds will be updated in the listing to signify as such.
Show full finding ▾Hide full finding ▴2021?002: EQUIPMENT TRACKING AND PURCHASES ? INTERNAL CONTROLS AND COMPLIANCE Federal Program Title(s): ? ALN 14.231 - Emergency Solutions Grant Program ? ALN 16.575 - Crime Victim Assistance Federal Agencies: ? Department of Housing and Urban Development (ALN 14.231) ? Department of Justice (ALN 16.575) Pass-Through Agencies: ? New Mexico Mortgage Finance Authority: (ALN 14.231) ? New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: ? 20-02-VSH-CAE-001 (7/27/2020-7/27/2022) (14.231) ? 2020-VA-880 (10/1/2019-9/30/2020) (16.575) ? 2021-VA-979 (10/1/2020-9/30/2021) (16.575) Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Per ?200.313, Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal Award Identification Number (FAIN)), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed to meet the federal requirements. Questioned costs: None. While VSS was not in compliance with the requirement for tracking and monitoring the federally procured equipment, there were no unallowed costs on equipment purchases made using federal funds. The material noncompliance relates to the context below, as there are no controls in place to ensure compliance with tracking and monitoring requirements. Context: The below issues were noted for both programs tested: ? During our testwork we noted no physical inventory was taken during the fiscal year ended June 30, 2021. ? The fixed asset listing does not contain the required information to properly identify purchases with federal funds. ? VSS does not currently tag assets purchased with federal monies. As such, due to the limited information present on invoices, we were not able to physically inspect all assets. ? -VSS does not have controls in place to track purchases with federal funds on a spreadsheet or similar. o (14.231) 1 of the 1 assets tested did not comply with federal requirements. o (16.575) 5 of the 5 assets tested did not comply with federal requirements. Cause: Lack of established controls and procedures over allowable costs principals, federal requirements for purchases using federal funds, and tracking of purchases made with federal funds. Effect: Possible noncompliance with federal cost principals and monitoring of assets purchased using federal funds. Repeat Finding: N/A ? New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. During this period, VSS was transitioning from remote work to back to the office due to COVID-19. Currently, we are back in the office and have started physical inventory. This includes taking of a physical inventory annually, any assets that were procured with federal funds in FY21 or in future years will be identified as such in the fixed asset listing, any assets that VSS has identified that have been previously acquired using federal funds will be updated in the listing to signify as such.
FEDERAL AGENCIES: DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (ALN 14.231) & DEPARTMENT OF JUSTICE (ALN 16.575) 20XX-002 Emergency Solutions Grant Program ? Assistance Listing No. 14.231 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. This should include policies for conducting a physical inventory of assets annually, updates to the fixed asset listing to ensure federal assets are identified, and tagging or identifying any federal assets both physically (with tags or numbers) and within the listing when no serial number is available. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. During this period, VSS was transitioning from remote work to back to the office due to COVID-19. Currently, we are back in the office and have started physical inventory. This includes taking of a physical inventory annually, any assets that were procured with federal funds in FY21 or in future years will be identified as such in the fixed asset listing, any assets that VSS has identified that have been previously acquired using federal funds will be updated in the listing to signify as such. Name(s) of the contact person(s) responsible for corrective action: Stephanie Wood, Executive Director Planned completion date for corrective action plan: 10/1/2022
During our testing, we noted that VSS internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Repeat Finding: N/A ? New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements.
Show full finding ▾Hide full finding ▴2021?003: PROCUREMENT/SUSPENSION AND DEBARMENT ? INTERNAL CONTROLS AND COMPLIANCE Federal Program Title(s): ? ALN 14.231 - Emergency Solutions Grant Program ? ALN 16.575 - Crime Victim Assistance Federal Agencies: ? Department of Housing and Urban Development (ALN 14.231) ? Department of Justice (ALN 16.575) Pass-Through Agencies: ? New Mexico Mortgage Finance Authority: (ALN 14.231) ? New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: ? 20-02-VSH-CAE-001 (7/27/2020-7/27/2022) (14.231) ? 20-02-VSH-EHA-001 (7/1/2020-6/30/2021) (14.231) ? 20-02-VSS-RAP-001 (7/1/2020-6/30/2021) (14.231) ? 2020-VA-880 (10/1/2019-9/30/2020) (16.575) ? 2021-VA-979 (10/1/2020-9/30/2021) (16.575) Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. VSS should have internal controls designed to ensure compliance with this provision. 2 CFR 200.318-200.321 outline requirements maintain records sufficient to detail the history of procurement, requirements for competition, methods and purchasing thresholds, as well as other requirements for contracting with organizations with using federal funds. VSS?s policies do not meet these requirements. Condition: During our testing, we noted that VSS internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Repeat Finding: N/A ? New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements.
FEDERAL AGENCIES: DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (ALN 14.231) & DEPARTMENT OF JUSTICE (ALN 16.575) 2021-003 Emergency Solutions Grant Program ? Assistance Listing No. 14.231 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. VSS internal controls and accounting policies were not sufficient in regards to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. Name(s) of the contact person(s) responsible for corrective action: Stephanie Wood, Executive Director Planned completion date for corrective action plan: 3/1/2023
During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals. Questioned costs: None Context: ? 14.231 - during our testwork over allowable costs principals we noted 44 of the 59 tested transactions did not have sufficient documentation of approval of allowability. ? 16.575 - during our testwork over allowable costs principals we noted 37 of the 56 tested transactions did not have sufficient documentation of approval of allowability. Cause: Lack of established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Repeat Finding: N/A ? New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals. During this period, VSS was transitioning from remote work to back to the office due to COVID-19. Currently, we are back in the office and have reinstated signing of all timesheets. Additionally, VSS has instated an accounts payable approval process, including signing off on invoices, to ensure all disbursements of federal funds receive approvals prior to charging to federal grants.
Show full finding ▾Hide full finding ▴2021?004: ALLOWABILITY ? INTERNAL CONTROLS OVER GENERAL DISBURSEMENTS AND PAYROLL Federal Program Title(s): ? ALN 14.231 - Emergency Solutions Grant Program ? ALN 16.575 - Crime Victim Assistance Federal Agencies: ? Department of Housing and Urban Development (ALN 14.231) ? Department of Justice (ALN 16.575) Pass-Through Agencies: ? New Mexico Mortgage Finance Authority: (ALN 14.231) ? New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: ? 20-02-VSH-CAE-001 (7/27/2020-7/27/2022) (14.231) ? 20-02-VSH-EHA-001 (7/1/2020-6/30/2021) (14.231) ? 20-02-VSS-RAP-001 (7/1/2020-6/30/2021) (14.231) ? 2020-VA-880 (10/1/2019-9/30/2020) (16.575) ? 2021-VA-979 (10/1/2020-9/30/2021) (16.575) Type of Finding: ? Material Weakness in Internal Control over Compliance Criteria or specific requirement: According to ?200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing, we noted that VSS internal controls were not sufficient or were not operating as designed in order to document approval of allowable costs principals. Questioned costs: None Context: ? 14.231 - during our testwork over allowable costs principals we noted 44 of the 59 tested transactions did not have sufficient documentation of approval of allowability. ? 16.575 - during our testwork over allowable costs principals we noted 37 of the 56 tested transactions did not have sufficient documentation of approval of allowability. Cause: Lack of established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Repeat Finding: N/A ? New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals. During this period, VSS was transitioning from remote work to back to the office due to COVID-19. Currently, we are back in the office and have reinstated signing of all timesheets. Additionally, VSS has instated an accounts payable approval process, including signing off on invoices, to ensure all disbursements of federal funds receive approvals prior to charging to federal grants.
FEDERAL AGENCIES: DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (ALN 14.231) & DEPARTMENT OF JUSTICE (ALN 16.575) 2021-004 Emergency Solutions Grant Program ? Assistance Listing No. 14.231 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals. Additionally, VSS should obtain approvals for general disbursements charged to grants and documentation of approval of time and effort by supervisor for all payroll costs charged to federal programs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals. During this period, VSS was transitioning from remote work to back to the office due to COVID-19. Currently, we are back in the office and have reinstated signing of all timesheets. Additionally, VSS has instated an accounts payable approval process, including signing off on invoices, to ensure all disbursements of federal funds receive approvals prior to charging to federal grants. Name(s) of the contact person(s) responsible for corrective action: Stephanie Wood, Executive Director Planned completion date for corrective action plan: 10/1/2022 for policy updates, 07/1/2022 was the date the accounts payable approval process took place.
During our testing, we noted VSS did not comply with the period of performance requirements. Context and Questioned Costs: During our testwork over period of performance we noted the following: ? (14.231) We noted that 2 of the 13 tested transactions were partially outside the period of performance. Total Questioned Costs of $366. ? (16.575) We noted that 4 of the 26 tested transactions were partially outside the period of performance. Total Questioned Costs of $720. Cause: Lack of established controls and procedures over period of performance requirements. Effect: Possible noncompliance with federal requirements and charging costs to unavailable funds outside the period of performance. Repeat Finding: N/A ? New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. VSS has also added this procedure to the end of grant checklist to ensure proper billing.
Show full finding ▾Hide full finding ▴2021?005: PERIOD OF PERFORMANCE ? INTERNAL CONTROLS AND COMPLIANCE OVER ALLOWABLE COSTS PRINCIPALS Federal Program Title(s): ? ALN 14.231 - Emergency Solutions Grant Program ? ALN 16.575 - Crime Victim Assistance Federal Agencies: ? Department of Housing and Urban Development (ALN 14.231) ? Department of Justice (ALN 16.575) Pass-Through Agencies: ? New Mexico Mortgage Finance Authority: (ALN 14.231) ? New Mexico Crime Victims Reparation Commission (ALN 16.575) Award Numbers and Periods: ? 20-02-VSH-EHA-001 (7/1/2020-6/30/2021) (14.231) ? 2020-VA-880 (10/1/2019-9/30/2020) (16.575) Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per ?200.309 Period of Performance, a non-federal entity may charge to the Federal Award only allowable costs incurred during the period of performance. Condition: During our testing, we noted VSS did not comply with the period of performance requirements. Context and Questioned Costs: During our testwork over period of performance we noted the following: ? (14.231) We noted that 2 of the 13 tested transactions were partially outside the period of performance. Total Questioned Costs of $366. ? (16.575) We noted that 4 of the 26 tested transactions were partially outside the period of performance. Total Questioned Costs of $720. Cause: Lack of established controls and procedures over period of performance requirements. Effect: Possible noncompliance with federal requirements and charging costs to unavailable funds outside the period of performance. Repeat Finding: N/A ? New Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. VSS has also added this procedure to the end of grant checklist to ensure proper billing.
FEDERAL AGENCIES: DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (ALN 14.231) & DEPARTMENT OF JUSTICE (ALN 16.575) 2021-005 Emergency Solutions Grant Program ? Assistance Listing No. 14.231 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements surrounding the requirements for period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS accepts this finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost principals and requirements. VSS has also added this procedure to the end of grant checklist to ensure proper billing. Name(s) of the contact person(s) responsible for corrective action: Stephanie Wood, Executive Director Planned completion date for corrective action plan: 10/1/2022
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