Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Condition: All Emergency Rental Assistance (ERA) grantees must submit monthly and quarterly reports. Monthly reports capture details specific to that month while quarterly reports contain several cumulative fields covering all activity from the date of the grant award through the quarter close. These reports provide financial and performance data regarding grantee administration of their ERA projects and capture program design in addition to program status data elements. Quarterly reports are intended to capture standard financial and performance data, as well as detailed information on qualifying direct and indirect expenditures pursuant to the government-wide Federal Funding Accountability and Transparency Act (FFATA) reporting requirements and in accordance with Section 15011 of the Coronavirus Aid, Relief, and Economic Security Act, as amended and interpreted in the U.S. Department of Treasury?s reporting and compliance guidance on Treasury.gov. The reports submitted by the Organization to the Sonoma County Community Development Commission inaccurately reported total expenditures to date due to a formula error. However, monthly expenditures reported and claimed for reimbursement were determined to be accurate. Cause: Internal controls over preparation of complete and accurate reporting were not properly implemented. Effect: The Organization reflected inaccurate information in the report submitted to the Sonoma County Community Development Commission. Questioned Cost: Not applicable. Recommendation: We recommend that the Organization develop and implement a more robust system for the preparation and submission of reporting data. The process should include a secondary review and approval of the report and underlying data by someone other than the preparer. Views of Responsible Officials: See Corrective Action Plan
Criteria: To be eligible, a household must be obligated to pay rent on a residential dwelling and the grantee must determine that: 1) one or more individuals within the household has qualified for unemployment benefits or experienced a reduction in household income, incurred significant costs, or experienced other financial hardship due, directly or indirectly, to the COVID-19 outbreak; 2) one or more individuals within the household can demonstrate a risk of experiencing homelessness or housing instability; and 3) the household has a household income at or below 80% of area median income. Grantees must obtain, if available, a current lease, signed by the applicant and the landlord or sublessor that identifies the unit where the applicant resides and establishes the rental payment amount. If a household does not have a signed lease, documentation of residence may include evidence of paying utilities for the residential unit, an attestation by a landlord who can be identified as the verified owner or management agent of the unit, or other reasonable documentation as determined by the grantee. In the absence of a signed lease, evidence of the amount of a rental payment may include bank statements, check stubs, or other documentation that reasonably establishes a pattern of paying rent, a written attestation by a landlord who can be verified as the legitimate owner or management agent of the unit, or other reasonable documentation as defined by the grantee in its policies and procedures. Condition: Disbursement of benefits under the program may have been made to individuals that were not eligible for benefits. Cause: The Organization implemented a process in which they performed a retrospective review of payments provided to select individuals. The Organization compared the names of landlord that were paid to public records to determine if the address agreed to the information submitted for eligibility determination. Upon review, the Organization determined payments may have been made to ineligible participants and submitted a report of their findings to the Sonoma County Development Community Commission. Effect: Ineligible participants may have received ineligible rental assistance. Questioned Cost: The Organization identified $111,275 in questionable rental assistance payments. Recommendation: We recommend the Organization compare the information submitted by applicants for eligibility to public records to determine validity prior to processing payments.
Criteria: The Uniform Guidance Subpart E provides the general provisions for allowable cost principles. Under the cost principles, expenses incurred must be ?measurable? and ?reasonable.? Condition: During our audit we noted the occurrence of gift card purchases, indicating that they were to be used for food purchases. However, there was no documentation that gift cards purchased by the Organization were ultimately used for purchases that were in compliance with applicable cost principles. Cause: Management?s understanding of the cost principles has not been fully developed. Effect: The Organization charged expenditures that did not meet the applicable cost principles to the Emergency Solutions Grants Program. Questioned Cost: $12,158. Recommendation: The Organization discontinue the practice of purchasing gift cards and maintain documentation to support all expenditures of program funds. We additionally recommend that management overseeing this program be provided training to improve their understanding of cost principles and allowable costs. Views of Responsible Officials: See Corrective Action Plan
Criteria: The Uniform Guidance Subpart E provides the general provisions for allowable cost principles. Under the cost principles, expenses incurred must be ?measurable? and ?reasonable.? Condition: During our audit we noted the occurrence of gift card purchases, indicating that they were to be used for food purchases. However, there was no documentation that gift cards purchased by the Organization were ultimately used for purchases that were in compliance with applicable cost principles. Cause: Management?s understanding of the cost principles has not been fully developed. Effect: The Organization charged expenditures that did not meet the applicable cost principles to the Emergency Solutions Grants Program. Questioned Cost: $12,158. Recommendation: The Organization discontinue the practice of purchasing gift cards and maintain documentation to support all expenditures of program funds. We additionally recommend that management overseeing this program be provided training to improve their understanding of cost principles and allowable costs. Views of Responsible Officials: See Corrective Action Plan
Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Condition: All Emergency Rental Assistance (ERA) grantees must submit monthly and quarterly reports. Monthly reports capture details specific to that month while quarterly reports contain several cumulative fields covering all activity from the date of the grant award through the quarter close. These reports provide financial and performance data regarding grantee administration of their ERA projects and capture program design in addition to program status data elements. Quarterly reports are intended to capture standard financial and performance data, as well as detailed information on qualifying direct and indirect expenditures pursuant to the government-wide Federal Funding Accountability and Transparency Act (FFATA) reporting requirements and in accordance with Section 15011 of the Coronavirus Aid, Relief, and Economic Security Act, as amended and interpreted in the U.S. Department of Treasury?s reporting and compliance guidance on Treasury.gov. The reports submitted by the Organization to the Sonoma County Community Development Commission inaccurately reported total expenditures to date due to a formula error. However, monthly expenditures reported and claimed for reimbursement were determined to be accurate. Cause: Internal controls over preparation of complete and accurate reporting were not properly implemented. Effect: The Organization reflected inaccurate information in the report submitted to the Sonoma County Community Development Commission. Questioned Cost: Not applicable. Recommendation: We recommend that the Organization develop and implement a more robust system for the preparation and submission of reporting data. The process should include a secondary review and approval of the report and underlying data by someone other than the preparer. Views of Responsible Officials: See Corrective Action Plan
Criteria: To be eligible, a household must be obligated to pay rent on a residential dwelling and the grantee must determine that: 1) one or more individuals within the household has qualified for unemployment benefits or experienced a reduction in household income, incurred significant costs, or experienced other financial hardship due, directly or indirectly, to the COVID-19 outbreak; 2) one or more individuals within the household can demonstrate a risk of experiencing homelessness or housing instability; and 3) the household has a household income at or below 80% of area median income. Grantees must obtain, if available, a current lease, signed by the applicant and the landlord or sublessor that identifies the unit where the applicant resides and establishes the rental payment amount. If a household does not have a signed lease, documentation of residence may include evidence of paying utilities for the residential unit, an attestation by a landlord who can be identified as the verified owner or management agent of the unit, or other reasonable documentation as determined by the grantee. In the absence of a signed lease, evidence of the amount of a rental payment may include bank statements, check stubs, or other documentation that reasonably establishes a pattern of paying rent, a written attestation by a landlord who can be verified as the legitimate owner or management agent of the unit, or other reasonable documentation as defined by the grantee in its policies and procedures. Condition: Disbursement of benefits under the program may have been made to individuals that were not eligible for benefits. Cause: The Organization implemented a process in which they performed a retrospective review of payments provided to select individuals. The Organization compared the names of landlord that were paid to public records to determine if the address agreed to the information submitted for eligibility determination. Upon review, the Organization determined payments may have been made to ineligible participants and submitted a report of their findings to the Sonoma County Development Community Commission. Effect: Ineligible participants may have received ineligible rental assistance. Questioned Cost: The Organization identified $111,275 in questionable rental assistance payments. Recommendation: We recommend the Organization compare the information submitted by applicants for eligibility to public records to determine validity prior to processing payments.
Criteria: The Uniform Guidance Subpart E provides the general provisions for allowable cost principles. Under the cost principles, expenses incurred must be ?measurable? and ?reasonable.? Condition: During our audit we noted the occurrence of gift card purchases, indicating that they were to be used for food purchases. However, there was no documentation that gift cards purchased by the Organization were ultimately used for purchases that were in compliance with applicable cost principles. Cause: Management?s understanding of the cost principles has not been fully developed. Effect: The Organization charged expenditures that did not meet the applicable cost principles to the Emergency Solutions Grants Program. Questioned Cost: $12,158. Recommendation: The Organization discontinue the practice of purchasing gift cards and maintain documentation to support all expenditures of program funds. We additionally recommend that management overseeing this program be provided training to improve their understanding of cost principles and allowable costs. Views of Responsible Officials: See Corrective Action Plan
Criteria: The Uniform Guidance Subpart E provides the general provisions for allowable cost principles. Under the cost principles, expenses incurred must be ?measurable? and ?reasonable.? Condition: During our audit we noted the occurrence of gift card purchases, indicating that they were to be used for food purchases. However, there was no documentation that gift cards purchased by the Organization were ultimately used for purchases that were in compliance with applicable cost principles. Cause: Management?s understanding of the cost principles has not been fully developed. Effect: The Organization charged expenditures that did not meet the applicable cost principles to the Emergency Solutions Grants Program. Questioned Cost: $12,158. Recommendation: The Organization discontinue the practice of purchasing gift cards and maintain documentation to support all expenditures of program funds. We additionally recommend that management overseeing this program be provided training to improve their understanding of cost principles and allowable costs. Views of Responsible Officials: See Corrective Action Plan