How should Service Coordinators prepare for ROSS program audits?
Formal audits of the ROSS program may be part of the overall PHA audit, or specific to the ROSS program. Independent public accounting firm (IPA) audits conducted by an outside company are required for PHAs that expend more than $750,000 in federal funds in a single fiscal year. An IPA audit is not required for PHAs that expend less than $750,000 in federal funds in a single fiscal year. However, HUD’s Office of the Inspector General may initiate an audit at any time for a PHA of any size.
The purpose of an audit is to ensure that ROSS grant funds are being used in compliance with program requirements, including paying for the salary of the Service Coordinator and administration of the ROSS program and not paying for direct services. ROSS Service Coordinators should refer to the NOFA from the fiscal year their grant was awarded to check program requirements and eligible uses of funds.
Best practice: audit binders
A well-organized set of audit binders can smooth the process for the grantee and the auditor. This section provides a list of binder “tabs,” or sections that ROSS Service Coordinators may want to create:
Section 1: ROSS Program Administration
- ROSS program NOFA
- HUD grant agreement
- Match letters and/or Memoranda of Understanding
- HUD form 52768
- Match tracking sheet
- Job descriptions and resumes for ROSS program staff
- Financial reports including the SF-425
- Expenses and corresponding invoices for salaries/fringe, training and travel, and administrative activities
Section 2: ROSS Program Operations
- ROSS marketing and outreach material (letters to community providers, brochures distributed to residents, posters or flyers)
- Resident sign-in sheets for programs organized by the Service Coordinator and appointments with the Service Coordinator
- Documentation from classes or programming to which the Service Coordinator referred clients (sign-in sheets, class materials)
Strong match letters
Strong match letters make it possible for auditors (and grant application reviewers) to accurately assess whether any matching funds, in-kind donations, or services provided meet HUD requirements. Strong match letters include the following elements:
- Detailed description of services to be provided;
- Clear calculation of both cash and in-kind match totals;
- Value per unit of service (and method of determining value if an in-kind donation);
- Projected number of participants to be served;
- Roles and responsibilities of the partners (ROSS grantee and provider); and
- Duration of the match agreement.