2023-001 – 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:
4 -- Missing documentation of landlord participation agreements,
1 -- Missing documentation of landlord participation agreements, due to incomplete record of transfer from WNCHS,
1 -- Missing documentation of lease contract,
2 – Missing documentation of housing assistance form.
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, 83 unique clients were served. We sampled 20 tenant files for multiple compliance requirements.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2022-002.
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.
2023-002 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 1 instance 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 20 tenant files were selected from a population of 83 tenants. The test found 1 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.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2022-004.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2023-001 – 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:
4 -- Missing documentation of landlord participation agreements,
1 -- Missing documentation of landlord participation agreements, due to incomplete record of transfer from WNCHS,
1 -- Missing documentation of lease contract,
2 – Missing documentation of housing assistance form.
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, 83 unique clients were served. We sampled 20 tenant files for multiple compliance requirements.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2022-002.
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.
2023-002 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 1 instance 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 20 tenant files were selected from a population of 83 tenants. The test found 1 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.
Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2022-004.
Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.