2022-001 Single Audit Submission
Significant Deficiency
Criteria: The Federal Office of Management and Budget (OMB) Circular 2 CFR 200.512(a) requires that a non-profit organization expending $750,000 or more in total cumulative Federal funds must have a Single Audit performed in accordance with the Single Audit Act. This audit reporting package must normally be submitted and received by the Federal Audit Clearinghouse (FAC) the earlier of 30 days after the report date or nine months after the fiscal year end. The due date for submission of WNCAP’s June 30, 2022, audit to the Clearinghouse was March 31, 2023.
Condition: The WNCAP Single Audit was not submitted to the Federal Audit Clearinghouse within the prescribed period.
Cause: Turnover in key finance positions along with COVID caused delays in the completion of the prior year audit which in turn affected the completion and timely filing of the current year Single Audit.
Effect: Management was not in compliance with the requirement to timely submit the Single Audit to the FAC.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-002.
Recommendation: Management should implement procedures ensure that the financial statements are submitted to the FAC in accordance with filing requirements.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2022-002 – Eligibility for Housing Assistance
Significant Deficiency
Criteria: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person’s family, including persons important to their care and well-being, as defined in 24 CFR 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information.
Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below:
14 – Missing Release of Information documentation,
9 -- Missing documentation of client and/or landlord participation agreements,
4 -- Missing documentation of current income or verification of 0 income,
3 – Missing documentation of housing plan or assessment.
Cause: The shift to remote work and varying levels of technical knowledge among staff on digital record keeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten. In addition, WNCAP was in the process of implementing Electronic Health Records (Apricot) when the COVID crisis began.
Effect: Compliance with eligibility could not be determined for some sampled tenants. Therefore, some ineligible individuals may have received assistance under the program.
Questioned Costs: Undeterminable
Context: During the year, 113 unique clients were served. We sampled 22 tenant files for multiple compliance requirements.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-003.
Recommendation: Management should implement internal control procedures to ensure that all required documentation for determining eligibility is obtained and included in each tenant file.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2022-003 – Unsupported Expenses
Significant Deficiency
(A) Activities Allowed or Unallowed
(B) Allowable Costs/Cost Principles
Criteria: HOPWA funds may be used to assist all forms of housing designed to prevent homelessness. Disbursements should be supported by verifiable audit evidence.
Condition: Disbursements were not supported by complete and verifiable evidence. The following errors were noted:
1-- Check amount did not agree with invoice amount for mileage reimbursement,
1 -- Missing or incomplete documentation
1 -- Check request was not signed by supervisor
1 – Check did not clear the bank within a reasonable time
Cause: The shift to remote work and varying levels of technical knowledge among staff on digital recordkeeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten.
Effect: Disbursements might have been made for unallowable activities or in violation of cost principles.
Questioned Costs: None
Context: 40 disbursements were reviewed out of a population of 1102.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-004.
Recommendation: We recommend that management improve internal controls over disbursements and supporting documentation to ensure that all necessary information is included in the client files. We also recommend that reconciliations be reviewed to determine that all checks have cleared and that there is follow-up on any that have not cleared within a reasonable time.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2022-004 Housing Quality Standards
Significant Deficiency
Criteria: All housing that involves acquisition, rehabilitation, conversion, lease, repair of facilities, new construction, project or tenant-based rental assistance, and operating costs must meet various housing quality standards listed in 24 CFR sections 574.310(b)(1)-(2).
Condition: During testing of tenant files, there were 5 instances where inspection documentation or HQS documentation was missing.
Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled.
Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards.
Questioned Cost: None
Context: A sample of 22 tenant files were selected from a population of 113 tenants. The test found 5 exceptions, as noted above.
Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2022-004 Housing Quality Standards
Significant Deficiency
Criteria: All housing that involves acquisition, rehabilitation, conversion, lease, repair of facilities, new construction, project or tenant-based rental assistance, and operating costs must meet various housing quality standards listed in 24 CFR sections 574.310(b)(1)-(2).
Condition: During testing of tenant files, there were 5 instances where inspection documentation or HQS documentation was missing.
Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled.
Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards.
Questioned Cost: None
Context: A sample of 22 tenant files were selected from a population of 113 tenants. The test found 5 exceptions, as noted above.
Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2022-001 Single Audit Submission
Significant Deficiency
Criteria: The Federal Office of Management and Budget (OMB) Circular 2 CFR 200.512(a) requires that a non-profit organization expending $750,000 or more in total cumulative Federal funds must have a Single Audit performed in accordance with the Single Audit Act. This audit reporting package must normally be submitted and received by the Federal Audit Clearinghouse (FAC) the earlier of 30 days after the report date or nine months after the fiscal year end. The due date for submission of WNCAP’s June 30, 2022, audit to the Clearinghouse was March 31, 2023.
Condition: The WNCAP Single Audit was not submitted to the Federal Audit Clearinghouse within the prescribed period.
Cause: Turnover in key finance positions along with COVID caused delays in the completion of the prior year audit which in turn affected the completion and timely filing of the current year Single Audit.
Effect: Management was not in compliance with the requirement to timely submit the Single Audit to the FAC.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-002.
Recommendation: Management should implement procedures ensure that the financial statements are submitted to the FAC in accordance with filing requirements.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2022-002 – Eligibility for Housing Assistance
Significant Deficiency
Criteria: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person’s family, including persons important to their care and well-being, as defined in 24 CFR 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information.
Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below:
14 – Missing Release of Information documentation,
9 -- Missing documentation of client and/or landlord participation agreements,
4 -- Missing documentation of current income or verification of 0 income,
3 – Missing documentation of housing plan or assessment.
Cause: The shift to remote work and varying levels of technical knowledge among staff on digital record keeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten. In addition, WNCAP was in the process of implementing Electronic Health Records (Apricot) when the COVID crisis began.
Effect: Compliance with eligibility could not be determined for some sampled tenants. Therefore, some ineligible individuals may have received assistance under the program.
Questioned Costs: Undeterminable
Context: During the year, 113 unique clients were served. We sampled 22 tenant files for multiple compliance requirements.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-003.
Recommendation: Management should implement internal control procedures to ensure that all required documentation for determining eligibility is obtained and included in each tenant file.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2022-003 – Unsupported Expenses
Significant Deficiency
(A) Activities Allowed or Unallowed
(B) Allowable Costs/Cost Principles
Criteria: HOPWA funds may be used to assist all forms of housing designed to prevent homelessness. Disbursements should be supported by verifiable audit evidence.
Condition: Disbursements were not supported by complete and verifiable evidence. The following errors were noted:
1-- Check amount did not agree with invoice amount for mileage reimbursement,
1 -- Missing or incomplete documentation
1 -- Check request was not signed by supervisor
1 – Check did not clear the bank within a reasonable time
Cause: The shift to remote work and varying levels of technical knowledge among staff on digital recordkeeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten.
Effect: Disbursements might have been made for unallowable activities or in violation of cost principles.
Questioned Costs: None
Context: 40 disbursements were reviewed out of a population of 1102.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-004.
Recommendation: We recommend that management improve internal controls over disbursements and supporting documentation to ensure that all necessary information is included in the client files. We also recommend that reconciliations be reviewed to determine that all checks have cleared and that there is follow-up on any that have not cleared within a reasonable time.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2022-004 Housing Quality Standards
Significant Deficiency
Criteria: All housing that involves acquisition, rehabilitation, conversion, lease, repair of facilities, new construction, project or tenant-based rental assistance, and operating costs must meet various housing quality standards listed in 24 CFR sections 574.310(b)(1)-(2).
Condition: During testing of tenant files, there were 5 instances where inspection documentation or HQS documentation was missing.
Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled.
Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards.
Questioned Cost: None
Context: A sample of 22 tenant files were selected from a population of 113 tenants. The test found 5 exceptions, as noted above.
Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2022-004 Housing Quality Standards
Significant Deficiency
Criteria: All housing that involves acquisition, rehabilitation, conversion, lease, repair of facilities, new construction, project or tenant-based rental assistance, and operating costs must meet various housing quality standards listed in 24 CFR sections 574.310(b)(1)-(2).
Condition: During testing of tenant files, there were 5 instances where inspection documentation or HQS documentation was missing.
Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled.
Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards.
Questioned Cost: None
Context: A sample of 22 tenant files were selected from a population of 113 tenants. The test found 5 exceptions, as noted above.
Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.