Finding 2023-002: Special Tests and Provisions; Rent Reasonableness Calculations
Federal Program Title: Department of Housing and Urban Development Assistance Listing No. 14.267 – Continuum of Care
Award year: IL1651L5T142002 August 1, 2021 – July 31, 2022; IL0315l5T142114 July 1, 2022 – June 30, 2023; IL1780L5T172100 and IL1651L5T142103 August 1, 2022 – July 31, 2023
Criteria: The Special Test provision for the Continuum of Care program requires that, where grants are used to pay for rent for all or part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly.
Condition: Documentation of rent reasonableness determination could not be located for program recipients whose rental units were located outside of the two main rental locations where participants are housed. The total costs associated with these units was $58,847.
Cause and Effect: There were no controls in place to ensure that rent reasonableness determinations be performed, and evidence of such calculations be maintained for the Rapid Rehousing grants. As a result, the cost of assistance may be disallowed.
Questioned Costs: $58,847
Context: A sample of 7 seven rental payments totaling $14,563 was selected from a population of payments totaling $271,155. The test found that 5 five of the payments, totaling $3,866, did not have documentation of rent reasonableness calculations. All 5 five of our exceptions related to the Rapid Rehousing grants. Total Rapid Rehousing costs make up $58,847 of the $271,155 population.
Repeat Finding: No.
Recommendation: We recommend that management perform a reasonableness review of all rental units under the program and should establish internal controls to ensure such calculations are performed and retained for all units going forward.
Views of Responsible Officials: Management agrees with this finding. See corrective action plan.
Finding 2023-003: Controls over Matching
Federal Program Title: Department of Housing and Urban Development Assistance Listing No. 14.267 – Continuum of Care
Award year: IL1651L5T142002 August 1, 2021 – July 31, 2022; IL0315l5T142114 July 1, 2022 – June 30, 2023; IL1780L5T172100 and IL1651L5T142103 August 1, 2022 – July 31, 2023
Criteria: 24 CFR section 578.73 requires that Continuum of Care grant recipients must match all grant funds, except for leasing funds, with at least 25 percen%t of cash or in-kind contributions from other sources on a grant-by-grant basis. In order to ensure compliance with this requirement, the Agency should have internal controls in place to monitor matching and should document the performance of those controls.
Condition: While we were able to test that the Agency was in compliance with the matching requirement, the Agency could not provide evidence of effective internal controls over the grant fund matching compliance requirement.
Cause and Effect: The Agency does not have sufficient controls in place to monitor this compliance requirement. The lack of control could result in the Agency not meeting the matching requirement which would represent a compliance exception and could impact future funding.
Questioned Costs: None identified.
Context: We tested compliance with the matching requirement for the three grants under this program which concluded during the audit period. We did not identify any noncompliance with the matching requirement as a result of our testing. However, the Agency did not have processes or controls in place to track the sources and uses of the match and monitor it throughout the agreement for proper compliance.
Repeat Finding: No.
Recommendation: We recommend that management implement a process to monitor the matching of grant funds for applicable grants and document performance of that control. This should include clear identification of the funds used for matching and their related sources.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2023-004: Data Collection Form Filing
Federal Program Title: Department of Housing and Urban Development Assistance Listing No. 14.267 – Continuum of Care; Department of Housing and Urban Development Assistance Listing No. 14.231 – COVID-19 – Emergency Solution Grants Program
Criteria: 2 CFR 200.512(a) requires that the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or 9 nine months after the end of the audit period.
Condition: The data collection form for the year ended June 30, 2023, will be filed after the March 31, 2024, deadline, making it a late submission.
Cause and Effect: The single audit was not completed as of the submission deadline. Late filing will result in the Agency not meeting the low-risk auditee criteria for the audit of the year ended June 30, 2024.
Questioned Costs: None identified.
Context: None
Repeat Finding: No.
Recommendation: We recommend that the Agency implement processes and controls to allow for a more timely audit.
Views of Responsible Officials: Management agrees with this finding. See corrective action plan.
Finding 2023-004: Data Collection Form Filing
Federal Program Title: Department of Housing and Urban Development Assistance Listing No. 14.267 – Continuum of Care; Department of Housing and Urban Development Assistance Listing No. 14.231 – COVID-19 – Emergency Solution Grants Program
Criteria: 2 CFR 200.512(a) requires that the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or 9 nine months after the end of the audit period.
Condition: The data collection form for the year ended June 30, 2023, will be filed after the March 31, 2024, deadline, making it a late submission.
Cause and Effect: The single audit was not completed as of the submission deadline. Late filing will result in the Agency not meeting the low-risk auditee criteria for the audit of the year ended June 30, 2024.
Questioned Costs: None identified.
Context: None
Repeat Finding: No.
Recommendation: We recommend that the Agency implement processes and controls to allow for a more timely audit.
Views of Responsible Officials: Management agrees with this finding. See corrective action plan.
Finding 2023-002: Special Tests and Provisions; Rent Reasonableness Calculations
Federal Program Title: Department of Housing and Urban Development Assistance Listing No. 14.267 – Continuum of Care
Award year: IL1651L5T142002 August 1, 2021 – July 31, 2022; IL0315l5T142114 July 1, 2022 – June 30, 2023; IL1780L5T172100 and IL1651L5T142103 August 1, 2022 – July 31, 2023
Criteria: The Special Test provision for the Continuum of Care program requires that, where grants are used to pay for rent for all or part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly.
Condition: Documentation of rent reasonableness determination could not be located for program recipients whose rental units were located outside of the two main rental locations where participants are housed. The total costs associated with these units was $58,847.
Cause and Effect: There were no controls in place to ensure that rent reasonableness determinations be performed, and evidence of such calculations be maintained for the Rapid Rehousing grants. As a result, the cost of assistance may be disallowed.
Questioned Costs: $58,847
Context: A sample of 7 seven rental payments totaling $14,563 was selected from a population of payments totaling $271,155. The test found that 5 five of the payments, totaling $3,866, did not have documentation of rent reasonableness calculations. All 5 five of our exceptions related to the Rapid Rehousing grants. Total Rapid Rehousing costs make up $58,847 of the $271,155 population.
Repeat Finding: No.
Recommendation: We recommend that management perform a reasonableness review of all rental units under the program and should establish internal controls to ensure such calculations are performed and retained for all units going forward.
Views of Responsible Officials: Management agrees with this finding. See corrective action plan.
Finding 2023-003: Controls over Matching
Federal Program Title: Department of Housing and Urban Development Assistance Listing No. 14.267 – Continuum of Care
Award year: IL1651L5T142002 August 1, 2021 – July 31, 2022; IL0315l5T142114 July 1, 2022 – June 30, 2023; IL1780L5T172100 and IL1651L5T142103 August 1, 2022 – July 31, 2023
Criteria: 24 CFR section 578.73 requires that Continuum of Care grant recipients must match all grant funds, except for leasing funds, with at least 25 percen%t of cash or in-kind contributions from other sources on a grant-by-grant basis. In order to ensure compliance with this requirement, the Agency should have internal controls in place to monitor matching and should document the performance of those controls.
Condition: While we were able to test that the Agency was in compliance with the matching requirement, the Agency could not provide evidence of effective internal controls over the grant fund matching compliance requirement.
Cause and Effect: The Agency does not have sufficient controls in place to monitor this compliance requirement. The lack of control could result in the Agency not meeting the matching requirement which would represent a compliance exception and could impact future funding.
Questioned Costs: None identified.
Context: We tested compliance with the matching requirement for the three grants under this program which concluded during the audit period. We did not identify any noncompliance with the matching requirement as a result of our testing. However, the Agency did not have processes or controls in place to track the sources and uses of the match and monitor it throughout the agreement for proper compliance.
Repeat Finding: No.
Recommendation: We recommend that management implement a process to monitor the matching of grant funds for applicable grants and document performance of that control. This should include clear identification of the funds used for matching and their related sources.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Finding 2023-004: Data Collection Form Filing
Federal Program Title: Department of Housing and Urban Development Assistance Listing No. 14.267 – Continuum of Care; Department of Housing and Urban Development Assistance Listing No. 14.231 – COVID-19 – Emergency Solution Grants Program
Criteria: 2 CFR 200.512(a) requires that the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or 9 nine months after the end of the audit period.
Condition: The data collection form for the year ended June 30, 2023, will be filed after the March 31, 2024, deadline, making it a late submission.
Cause and Effect: The single audit was not completed as of the submission deadline. Late filing will result in the Agency not meeting the low-risk auditee criteria for the audit of the year ended June 30, 2024.
Questioned Costs: None identified.
Context: None
Repeat Finding: No.
Recommendation: We recommend that the Agency implement processes and controls to allow for a more timely audit.
Views of Responsible Officials: Management agrees with this finding. See corrective action plan.
Finding 2023-004: Data Collection Form Filing
Federal Program Title: Department of Housing and Urban Development Assistance Listing No. 14.267 – Continuum of Care; Department of Housing and Urban Development Assistance Listing No. 14.231 – COVID-19 – Emergency Solution Grants Program
Criteria: 2 CFR 200.512(a) requires that the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or 9 nine months after the end of the audit period.
Condition: The data collection form for the year ended June 30, 2023, will be filed after the March 31, 2024, deadline, making it a late submission.
Cause and Effect: The single audit was not completed as of the submission deadline. Late filing will result in the Agency not meeting the low-risk auditee criteria for the audit of the year ended June 30, 2024.
Questioned Costs: None identified.
Context: None
Repeat Finding: No.
Recommendation: We recommend that the Agency implement processes and controls to allow for a more timely audit.
Views of Responsible Officials: Management agrees with this finding. See corrective action plan.