EIN: 936001547
UEI: KV4VMBHUWYH7
Audited by: CliftonLarsonAllen LLP
Cognizant agency: 14 [Department of Housing and Urban Development]
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Data as of September 2, 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 (154 days from today).
What is a management decision? →FAC accepted this audit on July 10, 2025 — management decision was due January 10, 2026.
The Authority did not have adequate internal controls designed to ensure that eligibility requirements were met. Questioned costs: Unable to determine Context: Testing of 40 tenant files for eligibility noted 15 files with exceptions: • 10 files were missing documentation needed to support and recalculate total income. • 5 files where the examination was not processed within the regulatory period. Cause: Home Forward did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: Home Forward is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using stale/inaccurate information in the rent calculation. Repeat Finding: Yes, finding 2023-002. Previously reported as a significant deficiency in internal control over compliance. Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and the income is supported. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Assistance Listing Number: 14.881 Federal Award Identification Number and Year: OR002VOW - 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Eligibility Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition: The Authority did not have adequate internal controls designed to ensure that eligibility requirements were met. Questioned costs: Unable to determine Context: Testing of 40 tenant files for eligibility noted 15 files with exceptions: • 10 files were missing documentation needed to support and recalculate total income. • 5 files where the examination was not processed within the regulatory period. Cause: Home Forward did not sufficiently monitor controls to ensure compliance with eligibility requirements. Effect: Home Forward is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using stale/inaccurate information in the rent calculation. Repeat Finding: Yes, finding 2023-002. Previously reported as a significant deficiency in internal control over compliance. Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and the income is supported. Views of responsible officials: There is no disagreement with the audit finding.
Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and the income is supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Prior to COVID, we had software controls in place that did not allow staff to override the next re-exam dates. We removed those restrictions during COVID. Since this audit finding we have now put those controls back in place. We also have training scheduled to discuss income calculations and to reiterate processes related to review schedules. The training will focus on correct income calculation procedures and documentation and will highlight maintaining effect dates for reviews when they are not completed on time due to resident failure to provide documentation. Name(s) of the contact person(s) responsible for corrective action: Elise Anderson (software controls) and Suzanne Couttouw (income/ exam date training) Planned completion date for corrective action plan: • Software controls back in place 6/1/2025 • Income Calculation training 7/16/2025
2023-002
FAC accepted this audit on September 28, 2024 — management decision was due March 28, 2025.
Home Forward is not in compliance with allowable cost requirements related to payroll. Questioned costs: $116 Context: For 1 of 40 payroll transactions tested, an erroneous $116 of additional pay was charged to the program. Cause: Home Forward did not sufficiently monitor controls to ensure compliance with payroll requirements. Effect: Home Forward is not in compliance with federal regulations regarding allowable costs for payroll. Repeat Finding: No. Recommendation: We recommend that Home Forward reviews the controls in place to ensure that payroll transactions charged to the program are supported. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: In accordance with Uniform Grant Guidance (2 CFR Part 200), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Home Forward is not in compliance with allowable cost requirements related to payroll. Questioned costs: $116 Context: For 1 of 40 payroll transactions tested, an erroneous $116 of additional pay was charged to the program. Cause: Home Forward did not sufficiently monitor controls to ensure compliance with payroll requirements. Effect: Home Forward is not in compliance with federal regulations regarding allowable costs for payroll. Repeat Finding: No. Recommendation: We recommend that Home Forward reviews the controls in place to ensure that payroll transactions charged to the program are supported. Views of responsible officials: There is no disagreement with the audit finding.
Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that payroll transactions charged to the program are supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Updated settings in payroll system so timesheet codes are available for selection only by the employees who should be using them. Added additional review of timesheet totals for certain codes. Will provide reminders and additional resources to supervisors on reviewing timesheets. Name(s) of the contact person(s) responsible for corrective action: Casey Little, Assistant Controller Planned completion date for corrective action plan: 8/31/2024
Home Forward is not in compliance with requirements related to eligibility. Questioned costs: Unable to determine. Context: For 1 of 40 files tested for public housing eligibility, family income and composition were not examined on a biennial basis and tenant income was not supported by 3rd party documentation. Cause: Home Forward did not sufficiently monitor controls to ensure compliance with eligibility requirements Effect: Home Forward is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using stale/inaccurate information in the rent calculation. Repeat Finding: No. Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and income is supported. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: Beneficiaries must be “low-income families,” as defined in Section 3(b)(2) of the 1937 Housing Act (42 USC 1437a(b)(2)) (Section 204(b) of Pub. L. No. 104-134 (42 USC 1437f (note))). Condition: Home Forward is not in compliance with requirements related to eligibility. Questioned costs: Unable to determine. Context: For 1 of 40 files tested for public housing eligibility, family income and composition were not examined on a biennial basis and tenant income was not supported by 3rd party documentation. Cause: Home Forward did not sufficiently monitor controls to ensure compliance with eligibility requirements Effect: Home Forward is not in compliance with federal regulations regarding eligibility. Tenant rent may have been miscalculated due to using stale/inaccurate information in the rent calculation. Repeat Finding: No. Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and income is supported. Views of responsible officials: There is no disagreement with the audit finding.
Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that recertifications are performed timely and income is supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • We will be conducting a random audit of all LRPH files. • Training on best practice for PH and PBV reviews. This training will emphasize the importance of proper income documentation. • Sending out monthly report for reviews that are coming due. Name(s) of the contact person(s) responsible for corrective action: Suzanne Couttouw, Compliance Manager (audit and training) and Elise Anderson (monthly reporting.) Planned completion date for corrective action plan: March 30, 2025
Home Forward is not in compliance with requirements related to suspension and debarment. Questioned costs: Unable to determine. Context: During our testing, it was noted that Home Forward did not review one of one vendors subject to the requirement prior to entering into a contract with the vendor to ensure the vendor did not have any active exclusion records. Cause: Home Forward did not anticipate spending federal funds under the contract. Effect: Home Forward is not in compliance with federal regulations that require verification to ensure that the business to which they have entered into a covered transaction is not excluded or disqualified, as specified in §180.300. Repeat Finding: No. Recommendation: We recommend Home Forward implements a process to ensure exclusion checks are done prior to the execution of a contract. This process should include a system to ensure documentation is maintained in the files evidencing the date of the exclusion check as well as documented review and approval of the results of the exclusion check by program staff. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the non-federal 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. According to §180.300 of 2 CFR Part 180, when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. This is done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: Home Forward is not in compliance with requirements related to suspension and debarment. Questioned costs: Unable to determine. Context: During our testing, it was noted that Home Forward did not review one of one vendors subject to the requirement prior to entering into a contract with the vendor to ensure the vendor did not have any active exclusion records. Cause: Home Forward did not anticipate spending federal funds under the contract. Effect: Home Forward is not in compliance with federal regulations that require verification to ensure that the business to which they have entered into a covered transaction is not excluded or disqualified, as specified in §180.300. Repeat Finding: No. Recommendation: We recommend Home Forward implements a process to ensure exclusion checks are done prior to the execution of a contract. This process should include a system to ensure documentation is maintained in the files evidencing the date of the exclusion check as well as documented review and approval of the results of the exclusion check by program staff. Views of responsible officials: There is no disagreement with the audit finding.
Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend Home Forward implements a process to ensure exclusion checks are done prior to the execution of a contract. This process should include a system to ensure documentation is maintained in the files evidencing the date of the exclusion check as well as documented review and approval of the results of the exclusion check by program staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement has updated the Contract Request form to include a section for attesting yes or no for federal funds, also allowing for free form entry. After a discussion with DCR on situations where they are unsure if there will be HUD funding it was determined to treat all their Public Improvement projects as Davis Bacon projects and include all applicable steps throughout the solicitation process. We are doing a full background check on all contracts, which includes a sam.gov check. When the contracts come to the Contracts and Procurement Manager for final signature, a check will be made in the file to confirm the documents are present showing the sam.gov screen print was made and the Contracts and Procurement Manager will sign both the background check and the Contract at that time. Example attached. Name(s) of the contact person(s) responsible for corrective action: Celeste King Planned completion date for corrective action plan: June 1, 2024
During our testing, we noted Home Forward did not have adequate internal controls designed to ensure the approval of comparables is formally documented in the files. Questioned costs: Unable to determine. Context: During our testing, it was noted that Home Forward did not formally document approval of comparables in 4 of 40 files. Cause: Home Forward has not been consistent with keeping formal documentation of approval of comparables in the files. Effect: The auditor noted no instances of noncompliance with the provisions of special tests and provisions - reasonable rental rates; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No. Recommendation: We recommend Home Forward design controls to ensure formal documentation of approval of comparables is in the files. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the non-federal 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. The Authority is required to establish a reasonable rent policy and ensure that policy is followed. Condition: During our testing, we noted Home Forward did not have adequate internal controls designed to ensure the approval of comparables is formally documented in the files. Questioned costs: Unable to determine. Context: During our testing, it was noted that Home Forward did not formally document approval of comparables in 4 of 40 files. Cause: Home Forward has not been consistent with keeping formal documentation of approval of comparables in the files. Effect: The auditor noted no instances of noncompliance with the provisions of special tests and provisions - reasonable rental rates; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No. Recommendation: We recommend Home Forward design controls to ensure formal documentation of approval of comparables is in the files. Views of responsible officials: There is no disagreement with the audit finding.
Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend Home Forward design controls to ensure formal documentation of approval of comparables is in the files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Home Forward will add clarifying language in our Shelter Plus Care (Continuum of Care) Program operating manual indicating need for staff to document who completed rent reasonableness reviews including signatures from program supervisors or department staff responsible for approving comparables when necessary as part of the rent reasonableness review. Additional staff training will be conducted during Shelter Plus Care and department team meetings. Name(s) of the contact person(s) responsible for corrective action: Ian Slingerland, Director of Homeless Initiatives and Supportive Housing Planned completion date for corrective action plan: 10/1/2024
FAC accepted this audit on September 28, 2023 — management decision was due March 28, 2024.
Home Forward provided payment for a contractor agreement that included wage rate requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 1 out of 5 contracts tested for wage rate requirements: ? Payment was made on a contract for which certified payrolls were required but not submitted. The sample was statistically valid. Cause: Home Forward did not follow the established procedures for payment of construction contracts subject to wage rate requirements. Effect: Home Forward is not in compliance with wage rate requirements. Repeat Finding: No. Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requirements. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: OR02VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Wage Rate Requirements Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Home Forward must do the following: ? As a condition to executing payment for a contract subject to wage rate requirements, require the contractor to submit to them weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: Home Forward provided payment for a contractor agreement that included wage rate requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 1 out of 5 contracts tested for wage rate requirements: ? Payment was made on a contract for which certified payrolls were required but not submitted. The sample was statistically valid. Cause: Home Forward did not follow the established procedures for payment of construction contracts subject to wage rate requirements. Effect: Home Forward is not in compliance with wage rate requirements. Repeat Finding: No. Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requirements. Views of responsible officials: There is no disagreement with the audit finding.
U.S. Department of Housing and Urban Development 2022-01 Moving to Work Demonstration Program ? Assistance Listing No. 14.881 Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Home Forward?s Procurement group will add an additional layer of contract review to the department?s quarterly review process. Procurement will begin review of the activity input into the agency?s certified payroll reporting system to compare to the payments made to contractors withing the period. Any payment activity will be cross referenced with the certified payroll to ensure receipt of Davis Bacon reporting has been submitted. Procurement will work with the Property Management group to resolve any items that require follow up with the contractors as a result of the review. Name(s) of the contact person(s) responsible for corrective action: Elise Anderson Planned completion date for corrective action plan: 12/31/2023.
Home Forward was unable to provide 2 out of 40 tenant files for review. Questioned costs: Unable to determine. Context: Out of 40 housing choice vouchers and low-income public housing tenant files tested, 2 tenant files were unable to be located. The sample was statistically valid. Cause: Home Forward did not follow the established procedures in its Low-Rent Public Housing Administrative Plan. Home Forward was not able to locate two eligibility files. Effect: Home Forward is not in compliance with eligibility requirements. Repeat Finding: No. Recommendation: We recommend Home Forward review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: OR02VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Eligibility Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Home Forward must do the following: ? As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). ? For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 982.516). ? Determine income eligibility and calculate the tenant?s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). ? Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Condition: Home Forward was unable to provide 2 out of 40 tenant files for review. Questioned costs: Unable to determine. Context: Out of 40 housing choice vouchers and low-income public housing tenant files tested, 2 tenant files were unable to be located. The sample was statistically valid. Cause: Home Forward did not follow the established procedures in its Low-Rent Public Housing Administrative Plan. Home Forward was not able to locate two eligibility files. Effect: Home Forward is not in compliance with eligibility requirements. Repeat Finding: No. Recommendation: We recommend Home Forward review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan. Views of responsible officials: There is no disagreement with the audit finding.
2022-02 Moving to Work Demonstration Program ? Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The files in question were moved from one office to another using Home Forward?s contracted courier system. Moving forward, any file that must be transported from one office to another will require the signature of the individual who is receiving the file as well as the individual relinquishing the file. The department will develop a new policy and train staff on the new procedure. In addition, the department will be conducting an audit of each site to assure that all files are present and accounted for. Name(s) of the contact person(s) responsible for corrective action: Elise Anderson, Celeste King Planned completion date for corrective action plan: 12/31/2023.
FAC accepted this audit on January 5, 2023 — management decision was due July 5, 2023.
FAC accepted this audit on September 22, 2021 — management decision was due March 22, 2022.
FAC accepted this audit on February 3, 2021 — management decision was due August 3, 2021.
FAC accepted this audit on July 9, 2019 — management decision was due January 9, 2020.
FAC accepted this audit on September 18, 2018 — management decision was due March 18, 2019.
FAC accepted this audit on September 24, 2017 — management decision was due March 24, 2018.
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GSA_MIGRATION
FAC accepted this audit on October 12, 2016 — management decision was due April 12, 2017.
GSA_MIGRATION
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