EIN: 911190193
UEI: FJAGB237SPB7
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 29, 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 29, 2027 (156 days from today).
What is a management decision? →For 1 out of 13 clients tested, a comparable unit analysis was not formally reviewed and approved. For 6 out of 13 clients tested, the comparable unit analysis was not reviewed and approved until significantly after the preparation of the form. For 5 out of 13 clients tested, comparable unit analysis was completed after tenant move-in, of which 2 were completed more than 20 days after move-in. Cause: LifeWire’s supervisory staff did not timely review the rent reasonableness documentation. An emphasis on completion of the forms was included in procedures, however management is continuing to enhance procedures related to the timing of preparation and completion in advance of client move-in. Effect or Potential Effect: Lack of timely review of the comparable unit analysis could result in charging of unallowed expenditures to the federal program. Questioned Costs: None. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Total costs subject to rent reasonableness were $947,816. Identification as a Repeat Finding: 2024-001. Recommendation: We recommend that LifeWire enforces the modified procedures to review approve, and retain rental reasonableness documentation, including the comparable unit analysis. Views of Responsible Officials: Management agrees with the finding that documentation was not timely reviewed. Management has modified its policies and procedures to ensure completion and review of rent reasonableness forms in a timely manner.
Show full finding ▾Hide full finding ▴Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: DA-202407-02980, DA-202407-02967, 00002098 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a 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 may not exceed rents currently being charged by the same owner for comparable unassisted space.” Per 24 CFR §578.49(b)(2) and §578.51(g), “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.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.” Condition: For 1 out of 13 clients tested, a comparable unit analysis was not formally reviewed and approved. For 6 out of 13 clients tested, the comparable unit analysis was not reviewed and approved until significantly after the preparation of the form. For 5 out of 13 clients tested, comparable unit analysis was completed after tenant move-in, of which 2 were completed more than 20 days after move-in. Cause: LifeWire’s supervisory staff did not timely review the rent reasonableness documentation. An emphasis on completion of the forms was included in procedures, however management is continuing to enhance procedures related to the timing of preparation and completion in advance of client move-in. Effect or Potential Effect: Lack of timely review of the comparable unit analysis could result in charging of unallowed expenditures to the federal program. Questioned Costs: None. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Total costs subject to rent reasonableness were $947,816. Identification as a Repeat Finding: 2024-001. Recommendation: We recommend that LifeWire enforces the modified procedures to review approve, and retain rental reasonableness documentation, including the comparable unit analysis. Views of Responsible Officials: Management agrees with the finding that documentation was not timely reviewed. Management has modified its policies and procedures to ensure completion and review of rent reasonableness forms in a timely manner.
Finding Number 2025-001 – Special Tests and Provisions (Rent Reasonableness) Corrective Action: What we've already been doing to correct the issue LifeWire has strengthened oversight within Services by consolidating the Services and Rapid Rehousing programs under a single Director, creating clearer accountability and consistency in implementation. Additionally, we have expanded our approval workflow to include multiple levels of review: Advocate → Manager → Director → Finance. This structured, multi-tiered review process increases oversight and enhances our ability to identify and address issues related to rent reasonableness documentation prior to payment. As part of this enhanced workflow, we require that internal audit practices occur at each level of approval, ensuring that rent reasonableness and comparable unit analysis documentation is reviewed for completeness, accuracy, and timeliness — and that review and approval occur prior to tenant move-in — before advancing to the next stage. At each level, reviewers will audit a minimum of 5% of files or 5 files per month, whichever is greater. What else we are putting in place LifeWire will continue to provide comprehensive training for all Services staff, including advocates, managers, and directors, focused on rent reasonableness requirements and the timing of comparable unit analysis completion and review. The Services Director is responsible for delivering and overseeing this training. This training will address the specific requirements outlined in 24 CFR §578.49 and §578.51 and reinforce expectations that documentation is completed, reviewed, andapproved prior to tenant move-in. All staff will be required to formally acknowledge completion ofthe training and their understanding of the updated requirements. Responsible Staff: Olivia Montgomery •Advocates (initial preparation of rent reasonableness and comparable unit analysisdocumentation) •Services Managers (first-level supervisory review and approval prior to move-in) •Services Director (program oversight and secondary review) •Executive Director (internal audit of Services Director approvals) •Finance Director / Finance Department (final review, approval, and payment oversight) Anticipated Completion Date: Enhancements are currently in progress, with full implementation and demonstrated compliance expected by Q3 2026.
2024-001
During our testing of direct costs (excluding salaries and related benefits), we noted in accordance with §200.403(g) that 2 of 43 transactions lacked underlying documentation to support the underlying expense for some, or all, of the expense. Cause: LifeWire did not have sufficient controls within the program services department to adequately document the nature of, and provide reconciling information, for the expenses prior to submission to the accounting department for payment. Effect or Potential Effect: Without adequate controls in place to ensure documentation is adequately maintained for costs, LifeWire could incorrectly charge expenditures to the federal programs. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs in 2025 were $1,053,085. The samples tested consisted of 43 transactions totaling $53,885. Questioned costs consist of amounts in excess of maintained documentation and totaled $1,931. For one transaction, only payment confirmation was retained, which did not include documentation of the nature of the expense. For the second transaction, LifeWire charged an amount in excess of the monthly lease payment and did not retain documentation to support the additional amount or nature of those costs. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support is appropriately maintained as required by §200.403 for all transactions. Views of Responsible Officials: Management agrees with the finding that documentation was not sufficiently maintained to support underlying expenditures. LifeWire has updated its policies and procedures to explicitly require that underlying documentation supporting the nature and amount of each expenditure be retained.
Show full finding ▾Hide full finding ▴Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: DA-202407-02980, DA-202407-02967, 00002098 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following criteria to be allowable under Federal awards: a)Be necessary and reasonable for the performance of the federal award and be allocablethereto under these principles. b)Conform to any limitations or exclusions set forth in these principles or in the Federal awardas to types or amount of cost items. c)Be consistent with policies and procedures that apply uniformly to both federally financedand other activities of the recipient or subrecipient. d)Be accorded consistent treatment. For example, a cost must not be assigned to a Federalaward as a direct cost if any other cost incurred for the same purpose in like circumstanceshas been allocated to the Federal award as an indirect cost. e)Be determined in accordance with generally accepted accounting principles (GAAP), except,for State and local governments and Indian Tribes only, as otherwise provided for in thispart. f)Not be included as a cost or used to meet cost sharing requirements of any other federallyfinanced program in either the current or a prior period. See § 200.306(b). g)Be adequately documented. See §200.300 through §200.309. h)Administrative closeout costs may be incurred until the due date of the final report(s). Ifincurred, these costs must be liquidated prior to the due date of the final report(s) andcharged to the final budget period of the award unless otherwise specified by the Federalagency. All other costs must be incurred during the approved budget period. At itsdiscretion, the Federal agency is authorized to waive prior written approvals to carryforward unobligated balances to subsequent budget periods. See §200.308(g)(3).” Condition: During our testing of direct costs (excluding salaries and related benefits), we noted in accordance with §200.403(g) that 2 of 43 transactions lacked underlying documentation to support the underlying expense for some, or all, of the expense. Cause: LifeWire did not have sufficient controls within the program services department to adequately document the nature of, and provide reconciling information, for the expenses prior to submission to the accounting department for payment. Effect or Potential Effect: Without adequate controls in place to ensure documentation is adequately maintained for costs, LifeWire could incorrectly charge expenditures to the federal programs. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs in 2025 were $1,053,085. The samples tested consisted of 43 transactions totaling $53,885. Questioned costs consist of amounts in excess of maintained documentation and totaled $1,931. For one transaction, only payment confirmation was retained, which did not include documentation of the nature of the expense. For the second transaction, LifeWire charged an amount in excess of the monthly lease payment and did not retain documentation to support the additional amount or nature of those costs. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support is appropriately maintained as required by §200.403 for all transactions. Views of Responsible Officials: Management agrees with the finding that documentation was not sufficiently maintained to support underlying expenditures. LifeWire has updated its policies and procedures to explicitly require that underlying documentation supporting the nature and amount of each expenditure be retained.
Corrective Action: What we've already been doing to correct the issue LifeWire has strengthened oversight within Services by consolidating the Services and Rapid Rehousing programs under a single Director, creating clearer accountability for expenditure documentation. The expanded multi-tier approval workflow (Advocate → Manager → Director → Finance) now includes a documentation completeness check at each stage, requiring that underlying support for all charges be attached and verified before a transaction advances toward payment. LifeWire has updated its policies and procedures to explicitly require that underlying documentation supporting the nature and amount of each expenditure be retained at the time the charge is generated from the program services department, consistent with 2 CFR §200.403(g). This will include clear guidance on what constitutes sufficient documentation (e.g., invoices, receipts, lease agreements, or other source documents) and the requirement that payment confirmation alone is not sufficient. What else we are putting in place LifeWire has implemented training for all Services staff on federal documentation standards, reinforcing that charges to federal programs must be supported by documentation that evidences both the nature and the amount of the expense. The Services Director is responsible for delivering and maintaining this training on an ongoing basis. All staff will be required to formally acknowledge completion of the training and their understanding of the updated requirements. Responsible Staff: Olivia Montgomery •Advocates and program staff (generating and attaching underlying documentation at pointof charge) •Services Managers (first level review for documentation completeness) •Services Director (program oversight and secondary review) •Executive Director (internal audit oversight; reviews Director of Services approvals andmonitors compliance) •Finance Director / Finance Department (final documentation review, approval, and paymentoversight) Anticipated Completion Date: Policy and procedure updates and staff training will be completed, with full implementation and demonstrated compliance expected by Q3 2026.
FAC accepted this audit on September 29, 2025 — management decision was due March 29, 2026.
For 3 out of 13 clients tested, a comparable unit analysis was not formally reviewed and approved. For 8 out of 13 clients tested, the comparable unit analysis was not reviewed and approved until significantly after the preparation of the form. For 9 out of 13 clients tested, comparable unit analysis was completed after tenant move in, of which 4 were completed more than 20 days after move in. Cause: Due to turnover, LifeWire’s staff did not timely review the rent reasonableness documentation until procedures were put into place after the deficiency was identified in the prior year audit. Therefore, the implementation of the control process in late 2024 caused the delay in the documented review of the comparable unit analyses. Effect or Potential Effect: Lack of timely review of the comparable unit analysis could result in charging of unallowed expenditures to the federal program. Questioned Costs: None. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Total costs subject to rent reasonableness were $662,077. Identification as a Repeat Finding: 2023-002. Recommendation: We recommend that LifeWire enforces the modified procedures to review approve, and retain rental reasonableness documentation, including the comparable unit analysis. Views of Responsible Officials: Management agrees with the finding that documentation was not timely reviewed. Management has modified its policies and procedures to ensure completion and review of rent reasonableness forms in a timely manner.
Show full finding ▾Hide full finding ▴Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: DA-202212-01187, DA-202407-02967, DA 202210 01319 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a 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 may not exceed rents currently being charged by the same owner for comparable unassisted space.” Per 24 CFR §§578.49(b)(2) and 578.51(g), “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.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.” Condition: For 3 out of 13 clients tested, a comparable unit analysis was not formally reviewed and approved. For 8 out of 13 clients tested, the comparable unit analysis was not reviewed and approved until significantly after the preparation of the form. For 9 out of 13 clients tested, comparable unit analysis was completed after tenant move in, of which 4 were completed more than 20 days after move in. Cause: Due to turnover, LifeWire’s staff did not timely review the rent reasonableness documentation until procedures were put into place after the deficiency was identified in the prior year audit. Therefore, the implementation of the control process in late 2024 caused the delay in the documented review of the comparable unit analyses. Effect or Potential Effect: Lack of timely review of the comparable unit analysis could result in charging of unallowed expenditures to the federal program. Questioned Costs: None. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Total costs subject to rent reasonableness were $662,077. Identification as a Repeat Finding: 2023-002. Recommendation: We recommend that LifeWire enforces the modified procedures to review approve, and retain rental reasonableness documentation, including the comparable unit analysis. Views of Responsible Officials: Management agrees with the finding that documentation was not timely reviewed. Management has modified its policies and procedures to ensure completion and review of rent reasonableness forms in a timely manner.
Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental payment request made with public funds. LifeWire’s AP approval process requires review and approval by members of the Director team before payments can be issued. In 2025, all rental payments made with CoC funds now have documented evidence of internal approval and review. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: The new process was rolled out in November 2024.
2023-002
We noted that certain individuals who work in certain departments complete time attestations to certify the time spent on and allocated to the grant for reimbursement. For 1 out of 47 selections, the employee approval of time attestation was not available. For 6 out of 47 selections, the employee attested to time that was less than what was allocated to the grant and no true-up was completed. Cause: LifeWire did not follow their procedures to review and reconcile the estimated amounts of payroll expenditures charged to the Continuum of Care to the actual expenditures for all employees. Effect or Potential Effect: Without adequate controls in place to reconcile the attestations to the costs based on budgeted allocations are appropriate and do not require adjustment, LifeWire could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement LifeWire is entitled to under the terms of the grants. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Total payroll costs for the Continuum of Care grants in 2024 were $609,817. Any payroll costs not adequately support by time and effort reports are considered questioned costs. Any payroll costs charged greater than attested time and effort reports are considered questions costs. Identification as a Repeat Finding: 2023-005. Recommendation: We recommend that LifeWire follow their procedures to review and reconcile the estimated amounts of payroll expenditures charged and that sufficient document be maintained to support any adjustments made as required by 2 CFR §200.430. Views of Responsible Officials: Management agrees with the finding. Management has modified policies and procedures to ensure staff time allocated to the grant is properly reviewed and approved and time and effort reports are completed by staff timely and documentation is retained.
Show full finding ▾Hide full finding ▴Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: DA-202212-01187, DA-202407-02967, DA 202210 01319 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation- Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that certain individuals who work in certain departments complete time attestations to certify the time spent on and allocated to the grant for reimbursement. For 1 out of 47 selections, the employee approval of time attestation was not available. For 6 out of 47 selections, the employee attested to time that was less than what was allocated to the grant and no true-up was completed. Cause: LifeWire did not follow their procedures to review and reconcile the estimated amounts of payroll expenditures charged to the Continuum of Care to the actual expenditures for all employees. Effect or Potential Effect: Without adequate controls in place to reconcile the attestations to the costs based on budgeted allocations are appropriate and do not require adjustment, LifeWire could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement LifeWire is entitled to under the terms of the grants. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Total payroll costs for the Continuum of Care grants in 2024 were $609,817. Any payroll costs not adequately support by time and effort reports are considered questioned costs. Any payroll costs charged greater than attested time and effort reports are considered questions costs. Identification as a Repeat Finding: 2023-005. Recommendation: We recommend that LifeWire follow their procedures to review and reconcile the estimated amounts of payroll expenditures charged and that sufficient document be maintained to support any adjustments made as required by 2 CFR §200.430. Views of Responsible Officials: Management agrees with the finding. Management has modified policies and procedures to ensure staff time allocated to the grant is properly reviewed and approved and time and effort reports are completed by staff timely and documentation is retained.
Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underlying the attestations were erroneous. In addition, LifeWire was not able to secure an attestation from a former employee before they departed the organization. In 2025, LifeWire is revising their attestation procedure such that contract-supported staff members will attest to the nature of their work instead of amounts of time to contracts. This will simplify the administrative burden of attestations and reduce opportunities for errors while still meeting our audit and contract funders’ requirements. We anticipate this revised method will be rolled out by the end of Q3-2025. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: Procedure rollout will be completed by the end of Q3-2025. Anticipated full compliance with the requirement will be in evidence through the end of 2025 and beyond.
2023-005
FAC accepted this audit on September 20, 2024 — management decision was due March 20, 2025.
LifeWire allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that one of the 60 samples selected for testing was incurred prior to the start of the applicable funding period and was not approved in accordance with §200.308. Cause: LifeWire did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period. Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, LifeWire could incorrectly charge expenditures to the federal programs. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Expenses in the first month of the grant period in 2023 were $63,132, with total expenses in 2023 of $358,191. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management agrees with the finding that policies and procedures were not properly in place to ensure costs were only charged as incurred during the funding period. Management modified its policies and procedures to obtain detailed clarification for period-end items from the contract manager ensuring properly included for reimbursement.
Show full finding ▾Hide full finding ▴Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Award/Pass-Through Entity Identifying Numbers: 202212-01122 Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. Condition: LifeWire allocated expenditures that were incurred prior to the start of the funding period. During our testing of costs, we noted that one of the 60 samples selected for testing was incurred prior to the start of the applicable funding period and was not approved in accordance with §200.308. Cause: LifeWire did not have policies and procedures in place to ensure that costs were only charged as incurred during the appropriate funding period. Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of the date of incurrence, LifeWire could incorrectly charge expenditures to the federal programs. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Expenses in the first month of the grant period in 2023 were $63,132, with total expenses in 2023 of $358,191. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management agrees with the finding that policies and procedures were not properly in place to ensure costs were only charged as incurred during the funding period. Management modified its policies and procedures to obtain detailed clarification for period-end items from the contract manager ensuring properly included for reimbursement.
o LifeWire’s Senior Accountants, Controller and Co-EDs carefully review all costs charged to contracts to ensure they fall within the appropriate contract period. As of September 9, 2024, all 2024 contract charges are captured in the correct periods. o If the staff of LifeWire has any question about the permissibility of a given charge, we will reach out to the contract manager, obtain clarification and/or permission in writing, and ensure that documentation is filed and maintained appropriately. If we are unable to obtain this permission, we will find another funding source for the charge or find alternate methods of supporting survivors’ needs. o Name of Responsible Individual: Jeannette Biffle, Controller
For 14 out of 19 clients tested, a comparable unit analysis was not completed for updated Housing and Urban Development (HUD) Fair Market Rates (FMR) or lease modifications prior to move in. Cause: LifeWire did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for LifeWire’s clients in need of rental assistance. LifeWire could incorrectly charge expenditures to the federal program as a result. Known Questioned Costs: $74,715 Likely Questioned Costs: $344,707 Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Total costs subject to rent reasonableness were $516,407. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that LifeWire enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined FMR requirements. Views of Responsible Officials: Management agrees with the finding that documentation was not appropriately retained or produced regarding rent reasonableness. Management has modified its policies and procedures to ensure completion of rent reasonableness to ensure compliance.
Show full finding ▾Hide full finding ▴Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 202212-01122, 202212-01115, DA-202212-01187, 202210-00966, DA-202212-01319 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a 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 may not exceed rents currently being charged by the same owner for comparable unassisted space.” Per 24 CFR §§578.49(b)(2) and 578.51(g), “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.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.” Condition: For 14 out of 19 clients tested, a comparable unit analysis was not completed for updated Housing and Urban Development (HUD) Fair Market Rates (FMR) or lease modifications prior to move in. Cause: LifeWire did not appropriately retain or produce documentation that rent reasonableness was checked prior to move-in or at changes to lease terms in accordance with its policies. Effect or Potential Effect: Insufficient retention or creation of rent reasonableness forms and supporting documentation resulted in rent reasonableness controls not operating effectively to appropriately identify rental amounts for LifeWire’s clients in need of rental assistance. LifeWire could incorrectly charge expenditures to the federal program as a result. Known Questioned Costs: $74,715 Likely Questioned Costs: $344,707 Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Total costs subject to rent reasonableness were $516,407. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that LifeWire enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring rental reasonableness documentation to ensure compliance with HUD-determined FMR requirements. Views of Responsible Officials: Management agrees with the finding that documentation was not appropriately retained or produced regarding rent reasonableness. Management has modified its policies and procedures to ensure completion of rent reasonableness to ensure compliance.
LifeWire’s advocacy team always strives to place survivors into housing where rent is reasonable and in line with fair market rates in eastern Washington. Though it was observed that all rents paid were comparable similar units in the area, our documentation was insufficient to prove we had performed these analyses. o After this oversight was brought to our attention, as of June 30, 2024, LifeWire has trained the Housing Team staff on the necessity of completing rent reasonableness evaluations for every participant placed in housing where their rent is paid by the Continuum of Care program. Rent reasonableness assessments are completed by participants’ assigned advocate, reviewed and approved by their supervisor, signed and dated in PDF format, and filed and maintained appropriately. o As of June 30, 2024, LifeWire has implemented an additional 90-day documentation review for every participant in this program. At the 90-day mark, supervisors on the Housing Team review all participant documents to ensure that all compliance requirements are met. o Name of Responsible Individual: Jeannette Biffle, Controller
For all four performance and financial reports submitted in relation to 2023 activity (two performance, and two financial), appropriate documentation was not available to evidence review of the reports prior to submission. Cause: While LifeWire has a policy in place that requires approval of reports prior to submission, proper documentation to support the policy was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. Questioned Costs: None. Context: There were two performance reports submitted and two financial reports submitted. All four reports were tested. This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that LifeWire implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that review and approval of reports was not maintained during the period under audit. Management has modified policies and procedures to maintain support for the control process.
Show full finding ▾Hide full finding ▴Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.251 Program: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Award/Pass-Through Entity Identifying Numbers: B-22-CP-WA-0956 Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For all four performance and financial reports submitted in relation to 2023 activity (two performance, and two financial), appropriate documentation was not available to evidence review of the reports prior to submission. Cause: While LifeWire has a policy in place that requires approval of reports prior to submission, proper documentation to support the policy was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. Questioned Costs: None. Context: There were two performance reports submitted and two financial reports submitted. All four reports were tested. This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that LifeWire implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that review and approval of reports was not maintained during the period under audit. Management has modified policies and procedures to maintain support for the control process.
o As of September 9, 2024, all outstanding required semiannual reports have been drafted by the Controller, approved by the Co-ED of Organizational Operations and submitted to HUD. All future required HUD reporting will be drafted by the Controller, reviewed and approved by the Co-ED of Organizational Operations, and subsequently submitted by the Controller by stated deadlines. Submitted reports will be filed and maintained appropriately. o On June 6, 2024 LifeWire requested to begin the close out process for this grant and is awaiting further instruction from HUD. When the close-out process is completed, no further reporting will be required for this grant. o Name of Responsible Individual: Jeannette Biffle, Controller
For all five Continuum of Care grants, appropriate documentation was not available to evidence review of the matching calculations prior to submission. Cause: While LifeWire has a policy in place that requires approval of matching calculations prior to submission, proper documentation to support the policy was not available. Effect or Potential Effect: Matching calculations could be submitted that are inaccurate or incomplete. Questioned Costs: None. Context: There were five active Continuum of Care grants in 2023. This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that LifeWire implement controls to ensure proper documentation of matching calculations and approval prior to submission. Views of Responsible Officials: Management agrees with the finding that review and approval of matching support was not maintained during the period under audit. Management has modified policies and procedures to maintain support for the control process.
Show full finding ▾Hide full finding ▴Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 202212-01122, 202212-01115, DA-202212-01187, 202210-00966, DA-202212-01319 Criteria: Recipients of federal awards must establish verifiable controls over matching calculations that are prepared and submitted. Condition: For all five Continuum of Care grants, appropriate documentation was not available to evidence review of the matching calculations prior to submission. Cause: While LifeWire has a policy in place that requires approval of matching calculations prior to submission, proper documentation to support the policy was not available. Effect or Potential Effect: Matching calculations could be submitted that are inaccurate or incomplete. Questioned Costs: None. Context: There were five active Continuum of Care grants in 2023. This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that LifeWire implement controls to ensure proper documentation of matching calculations and approval prior to submission. Views of Responsible Officials: Management agrees with the finding that review and approval of matching support was not maintained during the period under audit. Management has modified policies and procedures to maintain support for the control process.
o By September 30, 2024, following the guidance of our CoC contract manager, the LifeWire Finance staff will have revised and resubmitted CoC RFRs submitted in 2024 to reflect match funds appropriately. All RFRs will indicate written documentation of review and approval by the Co-ED of Organizational Operations for match fund calculations and support required by our funders. Documentation of reports, review and approval is filed and maintained appropriately. o Name of Responsible Individual: Jeannette Biffle, Controller
We noted that LifeWire allocated administrative payroll expenditures to Continuum of Care during 2023 based on budget allocation rates. There were no procedures in place to determine if a true-up was necessary from allocated costs. 27 timesheets were tested during the audit, of which five were charged based on budgets for the grant. Cause: LifeWire did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to Continuum of Care to the actual expenditures incurred. Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, LifeWire could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement LifeWire is entitle to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Payroll costs for administrative staff selected for testing totaled $1,185. Total payroll costs for the Continuum of Care grants in 2023 were $294,002. Any payroll costs not adequately supported by time and effort reports are considered questioned costs. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that LifeWire implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430. Views of Responsible Officials: Management agrees with the finding. Management has modified policies and procedures to ensure staff time allocated to the grant is properly reviewed and approved.
Show full finding ▾Hide full finding ▴Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: 202212-01122, 202212-01115, DA-202212-01187, 202210-00966, DA-202212-01319 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR §200.430 Compensation- Personal Services: “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non- Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.” Condition: We noted that LifeWire allocated administrative payroll expenditures to Continuum of Care during 2023 based on budget allocation rates. There were no procedures in place to determine if a true-up was necessary from allocated costs. 27 timesheets were tested during the audit, of which five were charged based on budgets for the grant. Cause: LifeWire did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to Continuum of Care to the actual expenditures incurred. Effect or Potential Effect: Without adequate controls in place to ensure costs based on budgeted allocations are reasonable and reconcile to the actual time spent on the program, LifeWire could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement LifeWire is entitle to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Payroll costs for administrative staff selected for testing totaled $1,185. Total payroll costs for the Continuum of Care grants in 2023 were $294,002. Any payroll costs not adequately supported by time and effort reports are considered questioned costs. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that LifeWire implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR §200.430. Views of Responsible Officials: Management agrees with the finding. Management has modified policies and procedures to ensure staff time allocated to the grant is properly reviewed and approved.
o As of June 30, 2024, LifeWire has implemented a new software package called VELA in which direct services staff enter their actual time worked to contracts, which is then reviewed and approved by their supervisors and reported to Finance staff for payroll processing. By December 31, 2024, the Finance staff will ensure all 2024 actual hours worked toward contracts have been reviewed and approved by all direct services staff whose time is billed and approved by their supervisors. o Name of Responsible Individual: Jeannette Biffle, Controller
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