Finding 2022-001 ? Allowable Costs and Activities ? Compliance and Control Finding Federal Award. No. 14.231 Emergency Solutions Grant Program ? COVID 19 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Missouri Department of Social Services Criteria Or Specific Requirement: 2 CFR sections 200.400 through 200.401 provide the general provisions for cost principles. Section 200.400(b) states that the non-Federal entity assumes responsibility of administering Federal funds in a manner consistent with underlying agreements, program objectives and the terms and conditions of the Federal award. Condition: In our nonstatistical sample of 40 transactions, we noted no exceptions as a result of our testing. However, during the current fiscal year, management of the Commission identified certain questionable rental assistance payments. Certain payments have been reported to the appropriate agencies in accordance with regulatory requirements and other payments are pending further investigation. Cause: The significant amount of Federal dollars awarded, the short period of time required to make awards available and the presence of new requirements for the program were burdensome for management to disburse in compliance with Federal guidelines. Compared to the Commission?s other Federal programs, the program involves a very large number of applications and a high volume of transactions resulting in exposure to error and irregularity. Effect: Instances of known and suspected noncompliance were identified by the Commission. Questioned Costs: $2,087,937 of costs are actively being investigated by the Commission. Of this amount, the Commission has identified $1,791,963 of known questioned costs and $295,974 of potential questioned costs that are still being investigated. Context: Approximately 1,300 vendors are set up in the Commission?s system for application of emergency rental assistance. Of the vendors with applications approved for funding, 133 are considered to be known noncompliance and 15 are being investigated for potential noncompliance. After the identification of the first instance of noncompliance, the Commission adjusted and enhanced its procedures for evaluating current and existing applications. As the Commission reviews future applications following their updated policies and procedures, additional vendors could be flagged to investigate prior payments for potential ineligible costs. Identification As A Repeat Finding: Repeat of Finding No. 2021-001. Recommendation: We recommend that management continue to apply resources devoted to mitigating and preventing further exposure to noncompliance. Additionally, we recommend the Commission continue to provide additional training to employees as well as third parties responsible for reviewing and approving applications. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Anticipated Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs
Finding 2022-001 ? Allowable Costs and Activities ? Compliance and Control Finding Federal Award. No. 14.231 Emergency Solutions Grant Program ? COVID 19 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Missouri Department of Social Services Criteria Or Specific Requirement: 2 CFR sections 200.400 through 200.401 provide the general provisions for cost principles. Section 200.400(b) states that the non-Federal entity assumes responsibility of administering Federal funds in a manner consistent with underlying agreements, program objectives and the terms and conditions of the Federal award. Condition: In our nonstatistical sample of 40 transactions, we noted no exceptions as a result of our testing. However, during the current fiscal year, management of the Commission identified certain questionable rental assistance payments. Certain payments have been reported to the appropriate agencies in accordance with regulatory requirements and other payments are pending further investigation. Cause: The significant amount of Federal dollars awarded, the short period of time required to make awards available and the presence of new requirements for the program were burdensome for management to disburse in compliance with Federal guidelines. Compared to the Commission?s other Federal programs, the program involves a very large number of applications and a high volume of transactions resulting in exposure to error and irregularity. Effect: Instances of known and suspected noncompliance were identified by the Commission. Questioned Costs: $2,087,937 of costs are actively being investigated by the Commission. Of this amount, the Commission has identified $1,791,963 of known questioned costs and $295,974 of potential questioned costs that are still being investigated. Context: Approximately 1,300 vendors are set up in the Commission?s system for application of emergency rental assistance. Of the vendors with applications approved for funding, 133 are considered to be known noncompliance and 15 are being investigated for potential noncompliance. After the identification of the first instance of noncompliance, the Commission adjusted and enhanced its procedures for evaluating current and existing applications. As the Commission reviews future applications following their updated policies and procedures, additional vendors could be flagged to investigate prior payments for potential ineligible costs. Identification As A Repeat Finding: Repeat of Finding No. 2021-001. Recommendation: We recommend that management continue to apply resources devoted to mitigating and preventing further exposure to noncompliance. Additionally, we recommend the Commission continue to provide additional training to employees as well as third parties responsible for reviewing and approving applications. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Anticipated Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs
Finding 2022-001 ? Allowable Costs and Activities ? Compliance and Control Finding Federal Award. No. 14.231 Emergency Solutions Grant Program ? COVID 19 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Missouri Department of Social Services Criteria Or Specific Requirement: 2 CFR sections 200.400 through 200.401 provide the general provisions for cost principles. Section 200.400(b) states that the non-Federal entity assumes responsibility of administering Federal funds in a manner consistent with underlying agreements, program objectives and the terms and conditions of the Federal award. Condition: In our nonstatistical sample of 40 transactions, we noted no exceptions as a result of our testing. However, during the current fiscal year, management of the Commission identified certain questionable rental assistance payments. Certain payments have been reported to the appropriate agencies in accordance with regulatory requirements and other payments are pending further investigation. Cause: The significant amount of Federal dollars awarded, the short period of time required to make awards available and the presence of new requirements for the program were burdensome for management to disburse in compliance with Federal guidelines. Compared to the Commission?s other Federal programs, the program involves a very large number of applications and a high volume of transactions resulting in exposure to error and irregularity. Effect: Instances of known and suspected noncompliance were identified by the Commission. Questioned Costs: $2,087,937 of costs are actively being investigated by the Commission. Of this amount, the Commission has identified $1,791,963 of known questioned costs and $295,974 of potential questioned costs that are still being investigated. Context: Approximately 1,300 vendors are set up in the Commission?s system for application of emergency rental assistance. Of the vendors with applications approved for funding, 133 are considered to be known noncompliance and 15 are being investigated for potential noncompliance. After the identification of the first instance of noncompliance, the Commission adjusted and enhanced its procedures for evaluating current and existing applications. As the Commission reviews future applications following their updated policies and procedures, additional vendors could be flagged to investigate prior payments for potential ineligible costs. Identification As A Repeat Finding: Repeat of Finding No. 2021-001. Recommendation: We recommend that management continue to apply resources devoted to mitigating and preventing further exposure to noncompliance. Additionally, we recommend the Commission continue to provide additional training to employees as well as third parties responsible for reviewing and approving applications. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Anticipated Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs
Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Finding Federal Award. No. 21.023 Emergency Rental Assistance Program ? COVID 19 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Missouri Department of Economic Development Criteria Or Specific Requirement: 2 CFR sections 200.400 through 200.401 provide the general provisions for cost principles. Section 200.400(b) states that the non-Federal entity assumes responsibility of administering Federal funds in a manner consistent with underlying agreements, program objectives and the terms and conditions of the Federal award. Condition: In our nonstatistical sample of 40 transactions, we noted no exceptions as a result of our testing. However, during the current fiscal year, management of the Commission identified certain questionable rental assistance payments. Certain payments have been reported to the appropriate agencies in accordance with regulatory requirements and other payments are pending further investigation. Cause: The significant amount of Federal dollars awarded, the short period of time required to make awards available and the presence of new requirements under a new program were burdensome for management to disburse in compliance with Federal guidelines. Compared to the Commission?s other Federal programs, the program involves a very large number of applications and a high volume of transactions resulting in exposure to error and irregularity. Effect: Instances of known and suspected noncompliance were identified by the Commission. Questioned Costs: $6,743,299 of costs are actively being investigated by the Commission. Of this amount, the Commission has identified $3,861,548 of known questioned costs and $2,881,751 of potential questioned costs that are still being investigated. Context: Approximately 20,000 vendors are set up in the Commission?s system for application of emergency rental assistance. Of the vendors with applications approved for funding, 172 are considered to be known noncompliance and 76 are being investigated for potential noncompliance. After the identification of the first instance of noncompliance, the Commission adjusted and enhanced its procedures for evaluating current and existing applications. As the Commission reviews future applications following their updated policies and procedures, additional vendors could be flagged to investigate prior payments for potential ineligible costs. Identification As A Repeat Finding: Repeat of Finding No. 2021-002. Recommendation: We recommend that management continue to apply resources devoted to mitigating and preventing further exposure to noncompliance. Additionally, we recommend the Commission continue to provide additional training to employees as well as third parties responsible for reviewing and approving applications. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. This includes the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that are responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021, the Commission hired an Internal Compliance Manager and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity continues to be expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as ?mass denial metrics? and tiered level reviews have been implemented into weekly application processing. Processes will continue to be implemented in response to changes in behavior by ineligible actors and ineligible application submission attempts. Commission staff has set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative measures demonstrated to be effective in other states. Anticipated Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs
Finding 2022-003 ? Reporting ? Compliance and Control Finding Federal Award. No. 21.023 Emergency Rental Assistance Program ? COVID 19 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Missouri Department of Economic Development Criteria Or Specific Requirement: 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. Condition: In our nonstatistical sample, we noted four monthly reports and one quarterly report of eight tested in which we were unable to agree identified ?Key Line Items? to the general ledger. For the monthly reports, the key line item noted was the ?Total amount of ERA funds expended by the ERA grantee to or for participating households on behalf of eligible households? line. For the quarterly report, the key line items were ?the cumulative amount obligated by the grantee? and ?the cumulative amount expended by the grantee?. Records supporting obligated amounts were not retained from the application database. The Commission?s general ledger accounts, which can include voided transactions, need to be reconciled to the application program details file. The process of reconciling and retaining the information used to create these reports was not in place throughout the entirety of the current year. Cause: Due to timing and staffing constraints, these reports were created from live files which were not reconciled with the general ledger prior to submission of the reports. Additionally, the live files in which the report were created were not retained by the Commission as supporting documentation for the amounts included in the reports submitted to the U.S. Treasury. Effect: The numbers reported to U.S. Treasury are not substantiated by supporting documentation such as a reconciliation, the general ledger or the live files that include program data. Questioned Costs: None Context: In our nonstatistical sample, we noted four monthly reports and one quarterly report of eight tested in which we were unable to agree identified ?Key Line Items? to the general ledger. Identification As A Repeat Finding: Not a repeat finding. Recommendation: The Commission should complete and retain reconciliations between the live program details file and the general ledger to support the amounts reported to U.S. Treasury. Views Of Responsible Officials: In order to navigate the required Department of Treasury reporting and to ensure that all reports reflect clear and appropriate information, staff has implemented many changes to process. To address staffing limitations, the Community Programs Processes Department was created in the fall of 2021 to aid in the reconciliation and financial tracking processes. In the early part of 2022, the Data and Analytics Department was officially formed to expand reporting capacity. New processes, in response to known limitations and timing restraints, have been developed to ensure adequate record keeping. Regular weekly meetings have been established between the Community Programs Processes Department, the Data and Analytics Department, and the Division Director to improve the coordination between all parties prior to the reporting deadlines. Additionally, where exceptions or changes must be made to reporting processes due to technical deficiencies or changes to guidance, processes have been established for clear communication and approval. Finally, as part of the regular coordination meetings, a debriefing of the reporting process occurs post submission so that improvements to the process may take place as needed. Anticipated Completion Date: The Commission developed new departments and added additional staffing in fall 2021 and early 2022. New processes for report completion, submission, and record keeping were developed in the late spring of 2022 and regular communication and process improvement are ongoing. The Commission expects to complete implementation of procedures and to document ERA report reconciliations with the general ledger during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs
Finding 2022-001 ? Allowable Costs and Activities ? Compliance and Control Finding Federal Award. No. 14.231 Emergency Solutions Grant Program ? COVID 19 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Missouri Department of Social Services Criteria Or Specific Requirement: 2 CFR sections 200.400 through 200.401 provide the general provisions for cost principles. Section 200.400(b) states that the non-Federal entity assumes responsibility of administering Federal funds in a manner consistent with underlying agreements, program objectives and the terms and conditions of the Federal award. Condition: In our nonstatistical sample of 40 transactions, we noted no exceptions as a result of our testing. However, during the current fiscal year, management of the Commission identified certain questionable rental assistance payments. Certain payments have been reported to the appropriate agencies in accordance with regulatory requirements and other payments are pending further investigation. Cause: The significant amount of Federal dollars awarded, the short period of time required to make awards available and the presence of new requirements for the program were burdensome for management to disburse in compliance with Federal guidelines. Compared to the Commission?s other Federal programs, the program involves a very large number of applications and a high volume of transactions resulting in exposure to error and irregularity. Effect: Instances of known and suspected noncompliance were identified by the Commission. Questioned Costs: $2,087,937 of costs are actively being investigated by the Commission. Of this amount, the Commission has identified $1,791,963 of known questioned costs and $295,974 of potential questioned costs that are still being investigated. Context: Approximately 1,300 vendors are set up in the Commission?s system for application of emergency rental assistance. Of the vendors with applications approved for funding, 133 are considered to be known noncompliance and 15 are being investigated for potential noncompliance. After the identification of the first instance of noncompliance, the Commission adjusted and enhanced its procedures for evaluating current and existing applications. As the Commission reviews future applications following their updated policies and procedures, additional vendors could be flagged to investigate prior payments for potential ineligible costs. Identification As A Repeat Finding: Repeat of Finding No. 2021-001. Recommendation: We recommend that management continue to apply resources devoted to mitigating and preventing further exposure to noncompliance. Additionally, we recommend the Commission continue to provide additional training to employees as well as third parties responsible for reviewing and approving applications. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Anticipated Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs
Finding 2022-001 ? Allowable Costs and Activities ? Compliance and Control Finding Federal Award. No. 14.231 Emergency Solutions Grant Program ? COVID 19 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Missouri Department of Social Services Criteria Or Specific Requirement: 2 CFR sections 200.400 through 200.401 provide the general provisions for cost principles. Section 200.400(b) states that the non-Federal entity assumes responsibility of administering Federal funds in a manner consistent with underlying agreements, program objectives and the terms and conditions of the Federal award. Condition: In our nonstatistical sample of 40 transactions, we noted no exceptions as a result of our testing. However, during the current fiscal year, management of the Commission identified certain questionable rental assistance payments. Certain payments have been reported to the appropriate agencies in accordance with regulatory requirements and other payments are pending further investigation. Cause: The significant amount of Federal dollars awarded, the short period of time required to make awards available and the presence of new requirements for the program were burdensome for management to disburse in compliance with Federal guidelines. Compared to the Commission?s other Federal programs, the program involves a very large number of applications and a high volume of transactions resulting in exposure to error and irregularity. Effect: Instances of known and suspected noncompliance were identified by the Commission. Questioned Costs: $2,087,937 of costs are actively being investigated by the Commission. Of this amount, the Commission has identified $1,791,963 of known questioned costs and $295,974 of potential questioned costs that are still being investigated. Context: Approximately 1,300 vendors are set up in the Commission?s system for application of emergency rental assistance. Of the vendors with applications approved for funding, 133 are considered to be known noncompliance and 15 are being investigated for potential noncompliance. After the identification of the first instance of noncompliance, the Commission adjusted and enhanced its procedures for evaluating current and existing applications. As the Commission reviews future applications following their updated policies and procedures, additional vendors could be flagged to investigate prior payments for potential ineligible costs. Identification As A Repeat Finding: Repeat of Finding No. 2021-001. Recommendation: We recommend that management continue to apply resources devoted to mitigating and preventing further exposure to noncompliance. Additionally, we recommend the Commission continue to provide additional training to employees as well as third parties responsible for reviewing and approving applications. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Anticipated Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs
Finding 2022-001 ? Allowable Costs and Activities ? Compliance and Control Finding Federal Award. No. 14.231 Emergency Solutions Grant Program ? COVID 19 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Missouri Department of Social Services Criteria Or Specific Requirement: 2 CFR sections 200.400 through 200.401 provide the general provisions for cost principles. Section 200.400(b) states that the non-Federal entity assumes responsibility of administering Federal funds in a manner consistent with underlying agreements, program objectives and the terms and conditions of the Federal award. Condition: In our nonstatistical sample of 40 transactions, we noted no exceptions as a result of our testing. However, during the current fiscal year, management of the Commission identified certain questionable rental assistance payments. Certain payments have been reported to the appropriate agencies in accordance with regulatory requirements and other payments are pending further investigation. Cause: The significant amount of Federal dollars awarded, the short period of time required to make awards available and the presence of new requirements for the program were burdensome for management to disburse in compliance with Federal guidelines. Compared to the Commission?s other Federal programs, the program involves a very large number of applications and a high volume of transactions resulting in exposure to error and irregularity. Effect: Instances of known and suspected noncompliance were identified by the Commission. Questioned Costs: $2,087,937 of costs are actively being investigated by the Commission. Of this amount, the Commission has identified $1,791,963 of known questioned costs and $295,974 of potential questioned costs that are still being investigated. Context: Approximately 1,300 vendors are set up in the Commission?s system for application of emergency rental assistance. Of the vendors with applications approved for funding, 133 are considered to be known noncompliance and 15 are being investigated for potential noncompliance. After the identification of the first instance of noncompliance, the Commission adjusted and enhanced its procedures for evaluating current and existing applications. As the Commission reviews future applications following their updated policies and procedures, additional vendors could be flagged to investigate prior payments for potential ineligible costs. Identification As A Repeat Finding: Repeat of Finding No. 2021-001. Recommendation: We recommend that management continue to apply resources devoted to mitigating and preventing further exposure to noncompliance. Additionally, we recommend the Commission continue to provide additional training to employees as well as third parties responsible for reviewing and approving applications. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Anticipated Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs
Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Finding Federal Award. No. 21.023 Emergency Rental Assistance Program ? COVID 19 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Missouri Department of Economic Development Criteria Or Specific Requirement: 2 CFR sections 200.400 through 200.401 provide the general provisions for cost principles. Section 200.400(b) states that the non-Federal entity assumes responsibility of administering Federal funds in a manner consistent with underlying agreements, program objectives and the terms and conditions of the Federal award. Condition: In our nonstatistical sample of 40 transactions, we noted no exceptions as a result of our testing. However, during the current fiscal year, management of the Commission identified certain questionable rental assistance payments. Certain payments have been reported to the appropriate agencies in accordance with regulatory requirements and other payments are pending further investigation. Cause: The significant amount of Federal dollars awarded, the short period of time required to make awards available and the presence of new requirements under a new program were burdensome for management to disburse in compliance with Federal guidelines. Compared to the Commission?s other Federal programs, the program involves a very large number of applications and a high volume of transactions resulting in exposure to error and irregularity. Effect: Instances of known and suspected noncompliance were identified by the Commission. Questioned Costs: $6,743,299 of costs are actively being investigated by the Commission. Of this amount, the Commission has identified $3,861,548 of known questioned costs and $2,881,751 of potential questioned costs that are still being investigated. Context: Approximately 20,000 vendors are set up in the Commission?s system for application of emergency rental assistance. Of the vendors with applications approved for funding, 172 are considered to be known noncompliance and 76 are being investigated for potential noncompliance. After the identification of the first instance of noncompliance, the Commission adjusted and enhanced its procedures for evaluating current and existing applications. As the Commission reviews future applications following their updated policies and procedures, additional vendors could be flagged to investigate prior payments for potential ineligible costs. Identification As A Repeat Finding: Repeat of Finding No. 2021-002. Recommendation: We recommend that management continue to apply resources devoted to mitigating and preventing further exposure to noncompliance. Additionally, we recommend the Commission continue to provide additional training to employees as well as third parties responsible for reviewing and approving applications. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views Of Responsible Officials: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. This includes the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that are responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021, the Commission hired an Internal Compliance Manager and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity continues to be expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as ?mass denial metrics? and tiered level reviews have been implemented into weekly application processing. Processes will continue to be implemented in response to changes in behavior by ineligible actors and ineligible application submission attempts. Commission staff has set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative measures demonstrated to be effective in other states. Anticipated Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs
Finding 2022-003 ? Reporting ? Compliance and Control Finding Federal Award. No. 21.023 Emergency Rental Assistance Program ? COVID 19 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Missouri Department of Economic Development Criteria Or Specific Requirement: 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. Condition: In our nonstatistical sample, we noted four monthly reports and one quarterly report of eight tested in which we were unable to agree identified ?Key Line Items? to the general ledger. For the monthly reports, the key line item noted was the ?Total amount of ERA funds expended by the ERA grantee to or for participating households on behalf of eligible households? line. For the quarterly report, the key line items were ?the cumulative amount obligated by the grantee? and ?the cumulative amount expended by the grantee?. Records supporting obligated amounts were not retained from the application database. The Commission?s general ledger accounts, which can include voided transactions, need to be reconciled to the application program details file. The process of reconciling and retaining the information used to create these reports was not in place throughout the entirety of the current year. Cause: Due to timing and staffing constraints, these reports were created from live files which were not reconciled with the general ledger prior to submission of the reports. Additionally, the live files in which the report were created were not retained by the Commission as supporting documentation for the amounts included in the reports submitted to the U.S. Treasury. Effect: The numbers reported to U.S. Treasury are not substantiated by supporting documentation such as a reconciliation, the general ledger or the live files that include program data. Questioned Costs: None Context: In our nonstatistical sample, we noted four monthly reports and one quarterly report of eight tested in which we were unable to agree identified ?Key Line Items? to the general ledger. Identification As A Repeat Finding: Not a repeat finding. Recommendation: The Commission should complete and retain reconciliations between the live program details file and the general ledger to support the amounts reported to U.S. Treasury. Views Of Responsible Officials: In order to navigate the required Department of Treasury reporting and to ensure that all reports reflect clear and appropriate information, staff has implemented many changes to process. To address staffing limitations, the Community Programs Processes Department was created in the fall of 2021 to aid in the reconciliation and financial tracking processes. In the early part of 2022, the Data and Analytics Department was officially formed to expand reporting capacity. New processes, in response to known limitations and timing restraints, have been developed to ensure adequate record keeping. Regular weekly meetings have been established between the Community Programs Processes Department, the Data and Analytics Department, and the Division Director to improve the coordination between all parties prior to the reporting deadlines. Additionally, where exceptions or changes must be made to reporting processes due to technical deficiencies or changes to guidance, processes have been established for clear communication and approval. Finally, as part of the regular coordination meetings, a debriefing of the reporting process occurs post submission so that improvements to the process may take place as needed. Anticipated Completion Date: The Commission developed new departments and added additional staffing in fall 2021 and early 2022. New processes for report completion, submission, and record keeping were developed in the late spring of 2022 and regular communication and process improvement are ongoing. The Commission expects to complete implementation of procedures and to document ERA report reconciliations with the general ledger during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs