Shiloh Home, Inc.

Federal Agency: U.S. Department of Health and Human Services

Assistance Listing Numbers: 21.027 & 93.623

Federal Program Titles: Coronavirus State and Local Fiscal Recovery Funds; Basic Center Grant

Type of Finding:

• Significant Deficiency in Internal Control over Compliance

Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.318, General procurement standards, requires that non-Federal entities must have documented procurement procedures, consistent with State and local laws and regulations for the acquisition of property or services required under a federal award and subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.326.

Condition: During our testing, we noted that the Organization’s procurement policy did not address all of the identified requirements in 2 CFR 200.318 through 200.326.

Questioned Costs: None.

Context: In our review of the current procurement policy, [the auditor] noted the following: • The policy did not include documented procedures for purchases above the simplified acquisition threshold ($250,000) in accordance with 2 CFR 200.320b. • The policy did not include documented procedures for the use and instances of noncompetitive procurement in accordance with 2 CFR 200.320c. • The policy did not include documented procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded as outlined in 2 CFR sections 200.212 and 200.318. • We also noted that the Organization did not verify that the entities with which it entered into contracts were not debarred, suspended, or otherwise excluded.

Effect: The Organization’s procurement policy is not in compliance with general procurement standards, and proper verification procedures for potentially suspended or debarred entities were not performed.

Repeat Finding: This is a repeat finding.

Recommendation: We recommend that the Organization update their procurement policy to address all requirements identified in 2 CFR 200.318 through 200.326.

Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Health and Human Services

Assistance Listing Numbers: 93.623

Federal Program Titles: Basic Center Grant

Type of Finding:

• Significant Deficiency in Internal Control over Compliance

Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal controls over federal awards. Furthermore, 2 CFR 200.403(g) requires that costs be adequately documented in order to be allowable under federal awards.

Condition: During our testing of expenditures charged to the major program, we noted multiple instances that did not contain documented evidence of review or approval by a supervisor or program manager.

Questioned Costs: None.

Context: During our testing of ten expenditures charged to the major program, we noted three instances that did not contain documented evidence of review or approval by a supervisor or program manager. Although management stated that expenditures are reviewed before processing, no signatures, initials, timestamps, or electronic workflow logs were retained to demonstrate the review occurred.

Effect: Failure to document review and approval increases the risk that unallowable or erroneous expenditures could be charged to the federal award and go undetected. Although no unallowable costs were identified in our testing, the control deficiency could lead to future noncompliance or questioned costs.

Repeat Finding: This is not a repeat finding.

Recommendation: We recommend that the Organization enforce policies requiring all expenditures charged to federal programs to be reviewed and approved by an appropriate official, and document the approval through dated signatures, electronic approvals, or maintained audit trails in software utilized by the Organization.

Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Health and Human Services

Assistance Listing Numbers: 93.623

Federal Program Titles: Transitional Living for Homeless Youth; Basic Center Grant

Type of Finding:

• Significant Deficiency in Internal Control over Compliance

Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.328, Financial Reporting, requires that non-Federal entities must submit quarterly Federal Financial Reports within the timeframe prescribed by the terms and conditions of the Federal award.

Condition: During our testing, we noted that the Organization did not submit the Federal Financial Reports within the timeframe outlined in the grant agreement.

Questioned Costs: None.

Context: During our testing of financial reports, [the auditor] noted the 2nd quarter and 4th quarter Federal Financial Reports for ALN 93.623 were submitted outside of the prescribed timeframe.

Effect: The organization is not compliant with the reporting requirements of the cognizant oversight agency.

Repeat Finding: This is not a repeat finding.

Recommendation: We recommend that the Organization implement a process to review the reporting requirements for all federal awards to ensure timely submission of reports.

Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 93.550 & 93.623 Federal Program Titles: Transitional Living for Homeless Youth; Basic Center Grant Award Period: October 1, 2022 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.318, General procurement standards, requires that non-Federal entities must have documented procurement procedures, consistent with State and local laws and regulations for the acquisition of property or services required under a federal award and subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.326. Condition: During our testing, we noted that the Organization’s procurement policy did not address all of the identified requirements in 2 CFR 200.318 through 200.326. Questioned Costs: None. Context: In our review of the current procurement policy, [the auditor] noted the following: The policy did not include documented procedures for purchases above the simplified acquisition threshold ($250,000) in accordance with 2 CFR 200.320b. The policy did not include documented procedures for the use and instances of noncompetitive procurement in accordance with 2 CFR 200.320c. The policy did not include documented procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded as outlined in 2 CFR sections 200.212 and 200.318. We also noted that the Organization did not verify that the entities with which it entered into contracts were not debarred, suspended, or otherwise excluded. Effect: The Organization’s procurement policy is not in compliance with general procurement standards, and proper verification procedures for potentially suspended or debarred entities were not performed. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization update their procurement policy to address all requirements identified in 2 CFR 200.318 through 200.326. Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 93.550 & 93.623 Federal Program Titles: Transitional Living for Homeless Youth; Basic Center Grant Award Period: October 1, 2022 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.328, Financial Reporting, requires that non-Federal entities must submit quarterly Federal Financial Reports within the timeframe prescribed by the terms and conditions of the Federal award. Condition: During our testing, we noted that the Organization did not submit the annual Federal Financial Report within the timeframe outlined in the grant agreement. Questioned Costs: None. Context: During our testing of performance and financial reports, [the auditor] noted the annual Federal Financial Reports for both ALNs 93.623 and 93.550 were submitted on January 26, 2024, which was four weeks past the deadline of December 30, 2023. Effect: The organization is not compliant with the reporting requirements of the cognizant oversight agency. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization implement a process to review the reporting requirements for all federal awards to ensure timely submission of reports. Views of Responsible Officials: Management agrees with the finding.