TRANSITION RESOURCE ACTION CENTER

Finding 2024‐001: Matching – Significant deficiency in internal controls over compliance and compliance finding. Continuum of Care Program ALN 14.267 Criteria: Per 2 CFR § 200.306, non‐federal entities are required to provide the level of matching (cost sharing) specified in the terms and conditions of the federal award. Matching contributions must be verifiable from the non‐federal entity’s records, not be included as contributions for any other federal award, and be necessary and reasonable for accomplishment of program objectives. Condition: During matching testing, the auditor noted the Organization did not meet the required 25% matching contribution specified in the award agreement. Questioned Costs: $21,917, representing the shortfall in matching contributions. Cause: In January and February of 2024, the Organization was transitioning from being a program of CitySquare to becoming an independent 501(c)(3). Following the transition, two staff members previously allocated to the match departed in September 2024, and their associated match was not reassigned. Effect: The Organization’s matching contributions did not meet the grant requirement in accordance with its internal control procedures over compliance. Failure to meet the required matching contribution may result in noncompliance with the terms and conditions of the federal award and could impact the allowability of federal expenditures claimed. The full amount of the federal expenditures may be subject to disallowance by the awarding agency. Recommendation: Management should implement controls to strengthen its grant management procedures to ensure all matching requirements are clearly understood, budgeted for, and monitored regularly. This includes assigning responsibility for tracking match contributions and reconciling them periodically to ensure compliance throughout the grant period. Management’s Response: See corrective action plan.

Finding 2024‐002: Allowable costs – Material weakness in internal controls over compliance. Continuum of Care Program ALN 14.267 Crime Victims Assistance ALN 16.575 Preparation for Adult Living HHS000705800003/ HHS000705500007 Criteria: Per 2 CFR §200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Such records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Time and effort documentation (e.g., timecards) should be signed by the employee and/or a supervisor with knowledge of the work performed. For state‐funded programs, similar documentation standards are typically required under TxGMS, which emphasize the need for adequate supporting documentation for payroll charges. Condition: During testing of payroll expenditures charged to both federal and state programs, the auditor noted that timecards for 80 out of 160 transactions tested were not signed by the supervisor. Questioned Costs: None Cause: At the time of the audit period, the Organization was newly independent from CitySquare and had not yet integrated supervisor approval of timecards into its internal control systems. This gap contributed to missing approvals during the transition year. Effect: Without properly signed timecards, there is an increased risk that payroll charges may not accurately reflect time worked on federal and state programs. This represents noncompliance with federal and state requirements and may result in disallowed costs. Recommendation: Management should implement controls to enforce a policy requiring all timecards to be signed by employees and approved by supervisors prior to payroll processing. The Organization should implement periodic reviews to ensure compliance with time and effort documentation requirements for all grant‐funded personnel. Management’s Response: See corrective action plan.

Finding 2024‐003: Allowable costs – Material weakness in internal controls over compliance and compliance finding. Continuum of Care Program ALN 14.267 Crime Victims Assistance ALN 16.575 Preparation for Adult Living HHS000705800003/ HHS000705500007 Criteria: Per 2 CFR §200.430 and the TxGMS, payroll costs charged to federal and state awards must be based on records that accurately reflect the work performed and must be supported by time and effort documentation. Charges to grants must be consistent with the actual distribution of time as documented by the employee. Additionally, expenditures charged to the grant must be supported by accurate accounting records, including alignment between timecards, payroll registers, and general ledger postings. Condition: During testing of payroll expenditures charged to both federal and state programs, the auditor noted that in 5 out of 160 transactions tested, the allocation percentages on the employee timecards did not reconcile to the payroll register and to the amount charged to the federal and state grant programs. Questioned Costs: None Cause: The exceptions resulted from delays in updating payroll/timekeeping systems and insufficient documentation to support allocation changes. Effect: Payroll expenditures did not accurately reconcile and align with actual time and effort records. This represents noncompliance with federal and state requirements and may result in disallowed costs. Recommendation: Management should implement controls to ensure amounts charged to the grants agree with timecards and payroll registers before requesting grant reimbursement. Management’s Response: See corrective action plan.