Identification of the Federal Program: Assistance Listing Number: 14.239 Assistance Listing Title: Home Investment Partnerships Program Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: M-17-MC-06-0559, M-18-MC-06-0559, M-19-MC-06-0559, M-20-MC-06-0559, M-21-MC-06-0559, M-22-MC-06-0559 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to November 2025 Compliance supplement, Eligibility: The HOME program has income targeting requirements. Only low-income or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR section 92.1). Therefore, the participating jurisdictions must determine if each family is income eligible by determining the family’s annual income, including all persons in the household, as provided for in 24 CFR section 92.203. The participating jurisdictions must maintain records for each family assisted (24 CFR section 92.508). Pursuant to 24 CFR section 92.216, Income targeting: Tenant-based rental assistance and rental units: Each participating jurisdiction must invest HOME funds made available during a fiscal year so that, with respect to tenant-based rental assistance and rental units: (a) Not less than 90 percent of: (1) The families receiving such rental assistance are families whose annual incomes do not exceed 60 percent of the median family income for the area, as determined and made available by HUD with adjustments for smaller and larger families (except that HUD may establish income ceilings higher or lower than 60 percent of the median for the area on the basis of HUD's findings that such variations are necessary because of prevailing levels of construction cost or fair market rent, or unusually high or low family income) at the time of occupancy or at the time funds are invested, whichever is later; or (2) The housing units assisted with such funds are occupied by families having such incomes; and (b) The remainder of: (1) The families receiving such rental assistance are households that qualify as low-income families (other than families described in paragraph (a)(1) of this section) at the time of occupancy or at the time funds are invested, whichever is later; or (2) The housing units assisted with such funds are occupied by such households. Condition: During our audit, we noted that in two (2) of the ten (10) samples selected for testing, changes were made to the rental assistance amounts determined by the City from the original eligibility and rental payment determinations. These changes were not adequately supported by the eligibility determination worksheets, nor was there evidence of appropriate review. Cause: The policies and procedures for the City's HOME funded Tenant Based Rental Assistance program were not very specific related to contractor requirements for file documentation maintenance regarding client income changes and corresponding rent subsidy changes. Effect or Potential Effect: The City could potentially be out of compliance and provide incorrect subsidy to participants or provide subsidy to ineligible participants. Questioned Costs: None. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation We recommend the City enhance its internal controls by updating its Tenant Based Rental Assistance program guidelines to provide specificity related to contractor requirements for file documentation maintenance regarding client income changes and corresponding rent subsidy changes. Views of Responsible Officials: Management concurs with the finding.
Finding 2025-001: Eligibility – Internal Control Over Eligibility Federal Award Information Assistance Listing Number: 14.239 Assistance Listing Title: Home Investment Partnerships Program Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: M-17-MC-06-0559, M-18-MC-06-0559, M-19-MC-06-0559, M-20-MC-06-0559, M-21-MC-06-0559, M-22-MC-06-0559 Name of Contact Person: Karen Roper, Housing & Homeless Solutions Manager Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to November 2025 Compliance supplement, Eligibility: The HOME program has income targeting requirements. Only low-income or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR section 92.1). Therefore, the participating jurisdictions must determine if each family is income eligible by determining the family’s annual income, including all persons in the household, as provided for in 24 CFR section 92.203. The participating jurisdictions must maintain records for each family assisted (24 CFR section 92.508). Pursuant to 24 CFR section 92.216, Income targeting: Tenant-based rental assistance and rental units: Each participating jurisdiction must invest HOME funds made available during a fiscal year so that, with respect to tenant-based rental assistance and rental units: (a) Not less than 90 percent of: (1) The families receiving such rental assistance are families whose annual incomes do not exceed 60 percent of the median family income for the area, as determined and made available by HUD with adjustments for smaller and larger families (except that HUD may establish income ceilings higher or lower than 60 percent of the median for the area on the basis of HUD's findings that such variations are necessary because of prevailing levels of construction cost or fair market rent, or unusually high or low family income) at the time of occupancy or at the time funds are invested, whichever is later; or (2) The housing units assisted with such funds are occupied by families having such incomes; and (b) The remainder of: (1) The families receiving such rental assistance are households that qualify as low-income families (other than families described in paragraph (a)(1) of this section) at the time of occupancy or at the time funds are invested, whichever is later; or (2) The housing units assisted with such funds are occupied by such households. Condition: During our audit, we noted that in two (2) of the ten (10) samples selected for testing, changes were made to the rental assistance amounts determined by the City from the original eligibility and rental payment determinations. These changes were not adequately supported by the eligibility determination worksheets, nor was there evidence of appropriate review. Cause: The policies and procedures for the City's HOME funded Tenant Based Rental Assistance program were not very specific related to contractor requirements for file documentation maintenance regarding client income changes and corresponding rent subsidy changes. Effect: The City could potentially be out of compliance and provide incorrect subsidy to participants or provide subsidy to ineligible participants. Questioned Costs: None. Context: See condition above for the context of the finding. Recommendation: We recommend the City enhance its internal controls by updating its Tenant Based Rental Assistance program guidelines to provide specificity related to contractor requirements for file documentation maintenance regarding client income changes and corresponding rent subsidy changes. Management Response and Corrective Action Plan: The City agrees with the above finding. Prior to the issuance of this monitoring report, the City conducted onsite monitoring of its TBRA contractor, Mercy House. The City’s monitoring report outlines the corrective action plan. Proposed Completion Date: This finding is considered to be resolved. The corrective action was taken as indicated in the Management Response and Corrective Action Plan above.
Finding 2020-001: Allowable Costs/ Cost Principles Noncompliance/Significant Deficiency Federal Award Information CFDA Number: 14.218 Program Title: Community Development Block Grant Federal Award Number: B-19-MC-06-0573 Federal Award Year: 2019 Name of Federal Agency: U.S. Department Housing and Urban Development Criteria or Specific Requirement The Community Development Block Grant Special Conditions require that if funding assistance is used for payment of indirect costs pursuant to 2 CFR 200, Subpart E - Cost Principles, the City must attach a schedule to the executed Grant Agreement that is returned to the U.S. Department of Housing and Urban Development(HUD). The schedule shall identify each department/agency that will carry out activities with the funding assistance, the indirect cost rate applicable to each department/agency (including if the de minimis rate is charged per 2 CFR ?200.414), and the direct cost base to which the rate will be applied. Condition Instance of Non-Compliance - The City is required to document indirect cost allocation plans for HUD?s review and approval. LSL noted through testwork that payroll costs lacked supporting documentation to determine the reasonableness of the expenditure as direct costs. It was then found that the mentioned costs were determined to be monthly indirect costs applied to this program. Additionally, percentages of salaries and benefits for administrative staff were charged to the grant each pay period, indirectly. The pay for 3 individuals was reimbursed as a percentage of the employees? regular salary. Cause of the Condition The City has not submitted a formal indirect cost allocation plan to the U.S. Department Housing and Urban Development. Effect or Possible Effect Failure to submit and document that indirect costs are reasonable administrative costs and/or carrying charges related to the planning and execution of community development activities can result in federal agency disallowing expenditures and noncompliance with the agreement. Not properly documenting all expenditures reimbursable by this grant can result in noncompliance with federal regulations regarding allowable costs/cost principles. Questioned Costs The indirect costs charged to the program for the year ended June 30, 2020 was $43,274. Context As a result of our testwork, it was noted that although indirect costs are allowed under this program, the monthly indirect costs reimbursed by this program lacked sufficient documentation to support the nature and amount of indirect costs applied. Recommendation We recommend that the City adhere to the Community Development Block Grant Special Conditions and submit an indirect cost allocation schedule, or only charge costs directly, with proper documentation supporting the direct time charged to the program
Finding 2019-001: Allowable Costs/ Cost Principles Noncompliance/Significant Deficiency Federal Award Information CFDA Number: 14.218 Program Title: Community Development Block Grant Federal Award Number: B-19-MC-06-0573 Federal Award Year: 2019 Name of Federal Agency: U.S. Department Housing and Urban Development Name of Contact Person: Cynthia Lara, Administrative Services Manager Criteria: The Community Development Block Grant Special Conditions require that if funding assistance is used for payment of indirect costs pursuant to 2 CFR 200, Subpart E - Cost Principles, the City must attach a schedule to the executed Grant Agreement that is returned to the U.S. Department of Housing and Urban Development (HUD). The schedule shall identify each department/agency that will carry out activities with the funding assistance, the indirect cost rate applicable to each department/agency (including if the de minimis rate is charged per 2 CFR ?200.414), and the direct cost base to which the rate will be applied. Condition: Instance of Non-Compliance - The City is required to document indirect cost allocation plans for HUD?s review and approval. LSL noted through testwork that payroll costs lacked supporting documentation to determine the reasonableness of the expenditure as direct costs. It was then found that the mentioned costs were determined to be monthly indirect costs applied to this program. Additionally, percentages of salaries and benefits for administrative staff were charged to the grant each pay period, indirectly. The pay for 3 individuals was reimbursed as a percentage of the employees? regular salary. Cause: The City has not submitted a formal indirect cost allocation plan to the U.S. Department Housing and Urban Development. Effect: Failure to submit and document that indirect costs are reasonable administrative costs and/or carrying charges related to the planning and execution of community development activities can result in federal agency disallowing expenditures and noncompliance with the agreement. Not properly documenting all expenditures reimbursable by this grant can result in noncompliance with federal regulations regarding allowable costs/cost principles. Questioned Costs: The indirect costs charged to the program for the year ended June 30, 2020 was $43,274. Context: As a result of our testwork, it was noted that although indirect costs are allowed under this program, the monthly indirect costs reimbursed by this program lacked sufficient documentation to support the nature and amount of indirect costs applied. Recommendation: We recommend that the City adhere to the Community Development Block Grant Special Conditions and submit an indirect cost allocation schedule, or only charge costs directly, with proper documentation supporting the direct time charged to the program. Management Response and Corrective Action Plan: The City agrees with the above finding. The City has already implemented a change to the time-keeping process to ensure that administrative staff's time charged is actual hours worked on the program, providing the proper documentation as noted in the finding. Proposed Completion Date: This finding is considered to be resolved. The corrective action was taken as indicated in the Management Response and Corrective Action Plan above.
Finding 2020-002: Allowable Costs/ Cost Principles Noncompliance/Significant Deficiency Federal Award Information CFDA Number: 20.507 Program Title: Federal Transit Cluster Federal Award Number: CA-2020-114-00 Federal Award Year: 2020 Name of Federal Agency: U.S. Department of Transportation Criteria or Specific Requirement The Federal Transit Grant requires that if funding assistance is used for payment of indirect costs pursuant to 2 CFR 200, Subpart E - Cost Principles, the City must notify the Granting Agency of the indirect cost rate applicable to each department/agency (including if the de minimis rate is charged per 2 CFR ?200.414), and the direct cost base to which the rate will be applied. Condition Instance of Non-Compliance - The City is required to document indirect cost allocation plans for the Department of Transportation?s review and approval. LSL noted through testwork that payroll costs lacked supporting documentation to determine the reasonableness of the expenditure as direct costs. It was then found that the mentioned costs were determined to be monthly indirect costs applied to this program. Additionally, percentages of salaries and benefits for administrative staff were charged to the grant each pay period, indirectly. The pay for 2 individuals was reimbursed as a percentage of the employees? regular salary. Cause of the Condition The City has not submitted a formal indirect cost allocation plan to the U.S. Department of Transportation Effect or Possible Effect Failure to submit and document that indirect costs are reasonable administrative costs and/or carrying charges related to the planning and execution of community development activities can result in federal agency disallowing expenditures and noncompliance with the agreement. Not properly documenting all expenditures reimbursable by this grant can result in noncompliance with federal regulations regarding allowable costs/cost principles. Questioned Costs The indirect costs charged to the program for the year ended June 30, 2020 was $16,308. Context As a result of our testwork, it was noted that although indirect costs are allowed under this program, the monthly indirect costs reimbursed by this program lacked sufficient documentation to support the nature and amount of indirect costs applied. Recommendation We recommend that the City adhere to the Uniform Guidance Requirements and submit an indirect cost allocation schedule, or only charge costs directly, with proper documentation supporting the direct time charged to the program.
Finding 2020-002: Allowable Costs/ Cost Principles Noncompliance/Significant Deficiency Federal Award Information CFDA Number: 20.507 Program Title: Federal Transit Cluster Federal Award Number: CA-2020-114-00 Federal Award Year: 2020 Name of Federal Agency: U.S. Department of Transportation Name of Contact Person: Sudesh Paul, Transportation Planning Supervisor Criteria: The Federal Transit Grant requires that if funding assistance is used for payment of indirect costs pursuant to 2 CFR 200, Subpart E - Cost Principles, the City must notify the Granting Agency of the indirect cost rate applicable to each department/agency (including if the de minimis rate is charged per 2 CFR ?200.414), and the direct cost base to which the rate will be applied. Condition: Instance of Non-Compliance - The City is required to document indirect cost allocation plans for the Department of Transportation?s review and approval. LSL noted through testwork that payroll costs lacked supporting documentation to determine the reasonableness of the expenditure as direct costs. It was then found that the mentioned costs were determined to be monthly indirect costs applied to this program. Additionally, percentages of salaries and benefits for administrative staff were charged to the grant each pay period, indirectly. The pay for 2 individuals was reimbursed as a percentage of the employees? regular salary. Cause: The City has not submitted a formal indirect cost allocation plan to the U.S. Department of Transportation Effect: Failure to submit and document that indirect costs are reasonable administrative costs and/or carrying charges related to the planning and execution of community development activities can result in federal agency disallowing expenditures and noncompliance with the agreement. Not properly documenting all expenditures reimbursable by this grant can result in noncompliance with federal regulations regarding allowable costs/cost principles. Questioned Costs: The indirect costs charged to the program for the year ended June 30, 2020 was $16,308. Context: As a result of our testwork, it was noted that although indirect costs are allowed under this program, the monthly indirect costs reimbursed by this program lacked sufficient documentation to support the nature and amount of indirect costs applied. Recommendation: We recommend that the City adhere to the Uniform Guidance Requirements and submit an indirect cost allocation schedule, or only charge costs directly, with proper documentation supporting the direct time charged to the program. Management Response and Corrective Action Plan: The City agrees with the above finding. The City has already implemented a change to the time-keeping process to ensure that administrative staff's time charged is actual hours worked on the program, providing the proper documentation as noted in the finding. Proposed Completion Date: This finding is considered to be resolved. The corrective action was taken as indicated in the Management Response and Corrective Action Plan above.
GSA_MIGRATION
GSA_MIGRATION
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and compliance status.
Start monitoring →Single Audit Intelligence is an independent tool powered by Federal Audit Clearinghouse data. Not affiliated with GSA, OMB, or any federal agency.