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Harris County Community Services Department. FINANCE ACCOUNTING SECTION LaKenya Wilson - Grant Accounting Manager Andrea Thomas – Senior Grant Accountant David Picazo - Grant Accountant. HUD Rule Citations. Nonprofits: 24 CFR Part 576 - Governing regulations

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harris county community services department
Harris County Community Services Department


LaKenya Wilson - Grant Accounting Manager

Andrea Thomas – Senior Grant Accountant

David Picazo - Grant Accountant

hud rule citations
HUD Rule Citations


24 CFR Part 576 - Governing regulations

42 U.S.C. 11375 - Matching requirements

24 CFR Part 84 - Procurement

2 CFR Part 215 (A-110) - Uniform Admin. Requirements

2 CFR Part 230 (A-122) - Cost Principles

OMB Circular A-133 - Audits


Please don’t forgetYOUR GRANT AGREEMENTwith Harris County.

financial mgmt system requirements
Financial Mgmt. System Requirements

Financial management systems are required to meet certain standards. Your financial systems must be able to:

  • Control & account for funds, property & other assets
  • Identifies source & application of funds
  • Allows for accurate, complete & timely reporting
  • Minimize the time between expending funds and seeking reimbursements from CSD
internal controls
Internal Controls

What are internal controls?

Internal controls are those measures taken by the organization for the purpose of:

  • Protecting resources against waste, fraud, and inefficiency by helping detect and prevent errors and/or abuses;
  • ensuring accuracy and reliability in accounting and operating data;
  • securing compliance with the policies of the organization; and
  • evaluating the level of performance in all organizational units of the organization.
internal controls5
Internal Controls

Effective controls provide reasonable assurance regarding the accomplishment of established objectives. An effective internal control system generally consists of five components:

  • Control Environment – Management integrity
  • Risk Assessment – Does management plan and think about the possibility of errors within certain activities
  • Control Activities – Has management employed policies and procedures designed to prevent certain errors
  • Information and Communication – Has management received feedback or reports as to the effectiveness of a procedure and has that information been communicated to involved individuals
  • Monitoring – Is there an independent verification function or internal audit function, or does management routinely spot check compliance with procedures
internal control system
Internal Control System

More specific examples and elements:

  • Organizational chart that provides clear definition of functional areas within your organization
  • Written delineation of job duties
  • Accounting policy & procedures
  • Separation of duties
  • Hiring policies
  • Control over assets & documents
  • Reconciliation of records
internal controls for budgeting
Internal Controls for Budgeting

Compare & control expenditures

  • Keep records on budgeted amounts
  • Compare obligations & expenditures to planned budgets & accomplishments
  • Report deviations from budgets & forecasts
accounting records
Accounting Records

Accounting system should include:

  • Chart of accounts
  • Cash receipts journal
  • Cash disbursements journal
  • Payroll journal
  • General ledger
accounting records cont d
Accounting Records (Cont’d)

Source documentation required (match/leverage included)

  • All expenditures must be supported by the appropriate source documentation: copies of canceled checks, invoices, purchase orders, receipts, time distribution reports, bank statements, etc.

Also, ensure that program costs were:

  • Expended on eligible items
  • Incurred for the proper period
  • Approved by appropriate officials
  • Actually paid
record retention
Record Retention
  • ESG records must be kept for 5 years after program year in which activity was funded: effectively 6 years
  • Recipients of federal funds are also responsible for proper recordkeeping and retention. Records should be sufficient to establish an audit trail for all transactions involving federal funds. An audit trail for federal funds starts with the preparation of the grant application or contract proposal and should include records adequate to support statements in the application document.
accounting records cont d11
Accounting Records (Cont’d)

Source documentation required for Homeless Prevention

  • copies of cancelled checks
  • lease agreements/deed of trusts with signatures
  • eviction notices
  • notices of termination

Financial Assistance is available to families who received eviction notices or utility service disconnect notice(s) if the following occurs:

  • Sudden reduction in income
  • Avoidance of eviction or utility termination
  • Reassurance of family’s ability to resume payments within reasonable period of time
  • ESG funds are not supplanting funds for preexisting homelessness prevention activities from other sources.
match requirements
Match Requirements
  • Each ESG sub-recipient, other than a territory, must match the funding provided by CSD with an equal amount of funds from other sources.
  • Matching funds must be related to expenditures occurring after the date of the grant award. Funds used to match a previous ESG grant may not be used to match a subsequent grant award.

42 U.S.C. 11375(a) contains match requirements

match requirements cont d
Match Requirements (Cont’d)

In general, matching funds provided may include:

  • Amount of funds from other sources;
  • Salary paid to staff (not included in the award) to carry out the project of the Grantee;
  • The value of any donated material or building, or of any lease, calculated using a reasonable method to establish a fair market value;
  • Time contributed by volunteers (currently determined at the rate of $5 per hour); and
  • Through matching funds or voluntary efforts provided by any recipient or project sponsor.
additional requirements
Additional Requirements

Additional financial rules apply:

  • Cost Principles
  • Audits (OMB A-133)
  • Procurement standards
cost principles
Cost Principles

Requirements can be found in 2 CFR Part 230 (OMB Circular A-122)

Three components to cost principles & Questions to Ask before incurring costs:

  • Cost reasonableness

Is the amount being claimed necessary and reasonable? a.k.a. (the prudent person test).

  • Cost allowability

Is the amount allowable under circulars and regulations?

  • Cost allocation

Can the amount be reasonably and accurately allocated to the program?

cost reasonableness
Cost Reasonableness

Costs charged to ESG must be necessary, reasonable & directly related to the grant.

Look at:

  • Whether cost is ordinary & necessary
  • Market prices for comparable goods/services
  • Individuals involved
cost allowability
Cost Allowability

In general, costs must be:

  • Statutorily allowed
  • Authorized or not expressly prohibited by regulations
  • Conform to & consistent with rules & requirements
  • Not charged to any other program
cost allocation
Cost Allocation

A cost is allocable to the program if it is:

  • Treated consistently with other similar costs
  • Incurred specifically for the program
  • Benefits program or can be distributed based on a reasonable proportion


  • Necessary to operations
direct indirect costs
Direct & Indirect Costs

Direct costs can be identified with a specific program or activity.

Indirect costs are incurred for common/joint purpose benefiting more than one program or activity

  • Administrative salaries
  • Accounting expenses
  • Facility maintenance
  • Federal programs are subject to review or audit
  • When spending $500,000.00 or more in “Federal awards” per year, specific rules apply
  • Grantees & Sub-recipients must adhere to OMB Circular A-133
procurement rules
Procurement Rules

Sub-recipients must adhere to Federal procurement rules in 24 CFR Part 84 when purchasing:

  • Services
  • Supplies & materials
  • Equipment

Procurement policies must be in place

Must follow written procedures & document compliance

important notice
Important Notice

Please be advised that “DIRECT DEPOSIT” is available.

financial forms
Financial Forms
  • Financial resources are available on the following websites:



  • As a “rule of thumb” GREEN and WHITE = GO & PINK, GREY and YELLOW = NO!!
  • Please refer to the Sub-recipient Accounting Procedures Manuals provided.
  • Also, failure to update the current invoice with any previous adjustments may postpone payment byAT LEAST2 weeks!!
technical assistance
Technical Assistance

Please don’t hesitate to seek Technical Assistance, if necessary!


Harris County Community Services Department


Vladimir Petsev – Finance Monitoring Manager

StevenDimayuga – Finance Monitor

PeterBroussard – Finance Monitor

financial monitoring
Financial Monitoring

When Does the Monitoring Process Start?

“It starts at the beginning”

CSD’s grant accountants and financial monitoring staff review the terms and details of the agreement and approved budgets at the start-up of your grant. This gives us a chance to plan our monitoring efforts and to see “what” and “how” your organization will deliver your ESG services.

financial monitoring27
Financial Monitoring

What Are The Types of Monitoring?

1.Desk Reviews – This is an on-going process through the lifespan of the grant. It entails:

A. A review of expenses for allowability, proper cost allocation, and a comparison to those expenses to the budget which are listed in the Financial Reporting portion of your monthly reimbursement requests.

B. A review of your annual audit by monitoring staff and the County Auditor’s Office. (note): You should receive a notification letter issued by the Co. Auditor’s requesting a copy of your audit.

financial monitoring28
Financial Monitoring

What Are The Types of Monitoring?

2. On-site Monitoring Visits – You may expect CSD to perform an annual and/or periodic visit ( when deemed necessary) as well as follow up visits to check on the progress of correcting noted concerns and/or findings.

Additionally, CSD’s Financial Monitoring section performs detailed testing & collection of source documentation in order to perform match verification during and near the program year end.

financial monitoring29
Financial Monitoring

What and How We Conduct Financial Monitoring for On-Site Visits

First, you’ll get a “Notification Letter”.

During the onsite visit we will:

  • Conduct an entrance conference, test and review compliance with Federal Regulations.
  • Review your Internal Controls Systems.
  • Review and verify eligibility of your match.
  • Based on sample testing, perform a detailed verification and determine the eligibility of expenditures you claimed.
  • Lastly, you’ll get a Monitoring Results Letter.
financial monitoring30
Financial Monitoring

Technical Assistance

If you need help….we are always available upon your request.

We can provide:

  • Resources and Templates
  • Sample policies and procedures
  • Knowledge and experience. And if we don’t know the answers to your questions, we’ll find them out for you.