Condition: Audit testing of a statistical sample of 15 cases processed during the year ended June 30, 2024, revealed the following:
One case where applicant income was calculated incorrectly; however, the income determination did not impact the amount of assistance allowed by DSHA’s policy.
Utility assistance was paid for two cases totaling $8,352.82 under the assumption that utility cost was $500 per month. Supporting utility bills, invoices, or statements were obtained to support the payment amount; however, support was not obtained to determine the actual number of months of utility assistance provided.
In January 2023, DHSA began paying utilities using $500 per month to calculate the number of months of utility assistance provided. This policy change was not included in policy documents and DSHA did not have evidence of appropriate internal approval for the policy change. Payments of $500 per month, up to the amount owed by applicants, were disbursed without determining the number of months of utility assistance provided.
A similar income determination finding was noted during the audit of the year ended June 30, 2023. Refer to Finding 2023-004.
Context: During the year ended June 30, 2024, DSHA approved and disbursed assistance for 80 rent assistance cases totaling $349,447 and 72 utility assistance cases totaling $114,905.
Criteria: The following summarizes the applicable portions of the ERA program requirements
United States Department of the Treasury Program FAQs updated May 10, 2023:
ERA 2 allows an eligible household to receive up to 15 months of assistance (plus an additional three (3) months, if necessary, to ensure housing stability for the household, subject to the availability of funds).
Grantees must establish policies and procedures to govern the implementation of their ERA programs consistent with the statutes and the ERA program requirements.
United States Department of the Treasury Program FAQs updated May 10, 2023, requires utility assistance payments to “…be supported by a bill, invoice or evidence of payment…” (FAQ # 6). The program requirements (FAQ #s 10 & 11) limit utility assistance to 18 months. While the program allows for estimated payments in certain circumstances (FAQ # 38), the program requires excess assistance to be recovered or paid by the disbursing agency from non-federal sources if the recipient is found to be ineligible or the assistance in excess of program requirements.
Questioned Costs: None
Effect: Internal controls were not operating effectively during the period. Additionally, a change to the utility assistance controls reduced their effectiveness.
Cause: Internal controls over compliance were not appropriately designed, implemented, or operated to appropriately address the risk of noncompliance with the federal program requirements.
On January 1, 2023, DSHA implemented a program design change to allow up to $500 a month in utility assistance. This threshold was used to calculate the number of months of assistance being provided instead of using the actual utility costs for 18 months.
Recommendation: We recommend DSHA enhance its policies and procedures for processing rental assistance applications to ensure compliance with the federal program’s requirements.
Condition: The following conditions were found during audit testing of two ERA 2 quarterly reports:
1. DSHA procedures over the reporting did not include the documentation of the preparation and review of quarterly reports selected for testing.
2. Audit testing of a statistical sample of 15 cases processed during the year ended June 30, 2024, revealed an income calculation on a case which resulted in the incorrect calculation of Area Median Income (AMI) percentage. The AMI percentages calculated at the case level are utilized to support required demographic reporting.
3. Supporting documentation was not retained for information on the reports selected for testing.
4. A review of the reports selected for testing revealed the following:
a. The demographic information section of the ERA 2 report for the quarter ended December 30, 2023, was not completed.
b. Evidence could not be provided showing how administrative and housing stability service amounts expended and obligated were calculated.
A similar finding was noted during the audit of the year ended June 30, 2023. Refer to finding 2023-005.
Criteria: United States Department of the Treasury ERA Program Reporting Guidance version 3.2 was issued March 29, 2022, provides detailed reporting requirements.
2 CFR § 200.303 requires the implementation of effective internal controls:
“Internal controls requires the non-federal entity to 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.”
Questioned Costs: None
Effect: Reports required by the U.S. Treasury were not submitted timely, accurately, and supported by contemporaneously prepared documentation. Information required for the U.S. Treasury to calculate the required reallocations was not accurately reported on the quarterly reports submitted.
Cause: Internal controls over reporting were not appropriately designed, implemented, or operated. DSHA’s internal controls over the reporting process did not ensure information required information was captured.
Recommendation: We recommend DSHA enhance its policies and procedures for preparing and approving required reports prior to submission.
Condition: Reconciliation of the HAF client assistance expenditures for the year ended June 30, 2023, revealed approximately $290,000 of federal funds were held by a vendor contracted to process and disburse client assistance and were reported as federal expenditures. This amount had increased to $433,522 by October 26, 2023. The funds were offset against assistance payments processed by the vendor on November 14, 2023. During the operation of the program, the vendor received refunds of client assistance that were not timely remitted to DSHA or utilized to fund assistance.
A similar finding was noted during the audit of the year ended June 30, 2023. Refer to finding 2023-006.
Criteria: The Uniform Guidance Cost Principles requires DSHA to offset credits against program expenditures in 2 CFR 200.406(a):
Applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect (F&A) costs. Examples of such transactions are purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate.
Questioned Costs: $433,522
Effect: The funds held by the vendor were initially recorded as program costs.
Cause: DSHA was notified, by the vendor, that a credit was available to be applied to fund future assistance. The vendor did not apply the credit without DSHA’s explicit approval, which was not granted until November 14, 2023.
Recommendation: We recommend DSHA review the design and implementation of internal controls to address the identified weaknesses in internal control.
Condition: Audit control and compliance testing of a statistical sample of 40 cases processed during the year ended June 30, 2024, revealed the following:
Applicant income was calculated incorrectly for four cases sampled, that resulted in these applicants receiving more months of Future Payment Assistance than allowed by DSHA’s policy, resulting in overpayments totaling $21,062.
Applicant income was calculated incorrectly for 11 cases sampled, which did not result in these applicants receiving more assistance than allowed by DSHA’s policy. One of these applicants received fewer months of Future Payment Assistance than allowed by DSHA’s policy.
Compliance testing performed on a separate sample of 33 cases revealed applicant income was calculated incorrectly for two cases sampled. These two applicants received more months of Future Payment Assistance than allowed by DSHA’s policy resulting in overpayments totaling $9,397.
Analysis of assistance for the period of July 1, 2023, through June 30, 2024, identified two homeowners that received in excess of $50,000 of mortgage assistance resulting in overpayments of assistance totaling $863.
A similar finding was noted during the audit of the year ended June 30, 2023. Refer to finding 2023-008.
Context: BLS applied DSHA’s written policies and reviewed forms used in application processing. The homeowner income verification process supports the following program functions:
Determination of allowable homeowner eligibility for assistance.
Determination of allowable Future Payment Assistance (starting in November 2022).
Required reporting of assistance by income level.
Compliance with the HAF Program Earmarking requirements.
Criteria:
Eligibility Criteria - DSHA submitted a HAF Grantee Plan to U.S. Department of the Treasury on May 31, 2022. DSHA’s HAF Grantee Plan specifies the following process for the determination of homeowner income:
DSHA intends to accept written attestations from DE-HAF applicants to ascertain eligibility for the programs (100% of AMI or 150% of AMI depending on the program). DSHA does not anticipate allowing the use of geographic area or other criteria not linked directly to the homeowner’s individual determinants. In addition, while eligibility will be determined with a pass/fail income threshold, later in the application review process a more specific income verification process will be required to establish the amount of monthly mortgage obligation that will be affordable to the homeowner. This income verification process will need to rely on substantiated documentation.
This process is consistent with United States Department of the Treasury Homeowner Assistance Fund Guidance issued on June 12, 2023.
DSHA’s HAF program began to provide Future Payment Assistance on November 13, 2022, as follows:
Applicants between 31.01% - 50% HDTI can be eligible for ‘Reinstatement’ plus up to 3 months of mortgage payments.
Applicants with ‘No Income’ or a HDTI 50.01% and above can be eligible for ‘Reinstatement’ plus up to 6 months of mortgage payments. *
*If in addition to the assistance, applicants will be referred to a HUD-approved Housing Counseling Agency to assist with an action plan beyond the assistance.
Earmarking Criteria - The United States Department of the Treasury Homeowner Assistance Fund Guidance issued on June 12, 2023, requires that at least 60% of amounts, made available to each HAF participant, be used for qualified expenses that assist homeowners having incomes equal to, or less than, 100% of the area median income, or equal to or less than 100% of the median income for the United States, whichever is greater. Any amount not made available to homeowners that meet this income-targeting requirement must be prioritized for assistance to socially disadvantaged individuals, with funds remaining after such prioritization being made available for other eligible homeowners.
Reporting Criteria - Homeowner Assistance Fund quarterly reporting requires the submission of Application Data disaggregated by Area Median Income.
Maximum Allowed Assistance - DSHA’s program design limited assistance to $50,000 during the year end June 30, 2024.
Questioned Costs: $31,322 of overpayments.
Effect: Federal program assistance was overpaid. Applicant income determined by assistance calculation process was used for compliance with earmarking requirements and to support required reporting by applicant income level resulting in potential errors in program reports submitted to the U.S. Treasury.
Cause: Homeowner assistance application processing did not correctly determine verified homeowner income.
Recommendation: We recommend DSHA enhance its policies and procedures for processing HAF assistance applications to ensure accurate calculation of verified homeowner income.
Condition: Testing of DSHA’s December 31, 2023, and June 30, 2024 HAF quarterly reports revealed the reports submitted by DSHA reported the same amounts as expended and obligated, for Administrative Expenses and Services, and Counseling & Education. During the year ended June 30, 2024, DSHA entered various contracts for the operation of the program.
DSHA’s Annual Report had an extended due date of November 23, 2023, but was not filed until November 29, 2023. Evidence of an additional extension could not be provided.
A similar finding was noted during the audit of the year ended June 30, 2023. Refer to finding 2023-009.
Criteria: The United States Department of the Treasury Homeowner Assistance Fund Guidance on Participant Compliance and Reporting Responsibilities includes the following definitions:
Expenditure/Expended means any HAF assistance that has been spent by a HAF participant and/or Subrecipient. Please note, cumulative Expenditures cannot exceed cumulative Obligations.
Obligation/Obligated means an order placed for property and services, contracts and subawards made, and similar transactions that require payment (see 2 CFR § 200.1.). Obligated funds include funds that have been Expended.
Examples of obligated funds include: HAF funds that have been committed, pledged, or otherwise promised, in writing, to a specific individual or entity as part of a HAF program; HAF funds that have been set aside to cover obligations arising from loan guarantees; HAF funds that have been committed, pledged, or otherwise promised, in writing, as part of a transaction; and HAF funds that have been committed, pledged, or promised, in writing, for allowable administrative expenses (e.g., an executed contract for services).
The Homeowner Assistance Fund: Annual Report User Guide Issued October 14, 2022 (Updated October 13, 2023), requires the reporting of outcomes for assistance provided to Homeowners by Area Median Income and Socially Disadvantaged Individuals.
Questioned Costs: None
Effect: Reports required by the U.S. Treasury were not supported by contemporaneously prepared supporting documentation. Reports submitted to the U.S. Treasury did not include accurate reporting of program obligations. Reports required by the U.S. Treasury were not submitted timely.
Cause: The report preparation process did not consider executed contracts and agreements to be obligations.
Recommendation: We recommend DSHA enhance its policies and procedures for preparing and approving required reports prior to submission.
Condition: DSHA’s ERA program included various steps to monitor program disbursements for potential fraud. These monitoring processes were performed during the assistance determination process and by after-the-fact analysis and reviews. DSHA’s after-the-fact processes identified 17 households that potentially received $168,055 in fraudulent assistance during the program’s operation. As of June 30, 2024, the uncollected balance was $82,709. DSHA identified this potentially fraudulent assistance and recovered a portion but did not further pursue resolution of the matter.
Criteria: The Emergency Rental Assistance program FAQ specifically requires DSHA “…to investigate and address potential instances of fraud or the misuse of funds that they become aware of.”
Questioned Costs: $82,709
Effect: Assistance was potentially provided to ineligible applicants due to fraudulent submissions.
Cause: Internal controls over eligibility were not able to prevent or detect and correct potentially fraudulent behavior by applicants.
Recommendation: We recommend DSHA further investigate, and report fraud or potential fraud as required by the CFR and program guidelines.
Condition: Audit testing of a statistical sample of 15 cases processed during the year ended June 30, 2024, revealed the following:
One case where applicant income was calculated incorrectly; however, the income determination did not impact the amount of assistance allowed by DSHA’s policy.
Utility assistance was paid for two cases totaling $8,352.82 under the assumption that utility cost was $500 per month. Supporting utility bills, invoices, or statements were obtained to support the payment amount; however, support was not obtained to determine the actual number of months of utility assistance provided.
In January 2023, DHSA began paying utilities using $500 per month to calculate the number of months of utility assistance provided. This policy change was not included in policy documents and DSHA did not have evidence of appropriate internal approval for the policy change. Payments of $500 per month, up to the amount owed by applicants, were disbursed without determining the number of months of utility assistance provided.
A similar income determination finding was noted during the audit of the year ended June 30, 2023. Refer to Finding 2023-004.
Context: During the year ended June 30, 2024, DSHA approved and disbursed assistance for 80 rent assistance cases totaling $349,447 and 72 utility assistance cases totaling $114,905.
Criteria: The following summarizes the applicable portions of the ERA program requirements
United States Department of the Treasury Program FAQs updated May 10, 2023:
ERA 2 allows an eligible household to receive up to 15 months of assistance (plus an additional three (3) months, if necessary, to ensure housing stability for the household, subject to the availability of funds).
Grantees must establish policies and procedures to govern the implementation of their ERA programs consistent with the statutes and the ERA program requirements.
United States Department of the Treasury Program FAQs updated May 10, 2023, requires utility assistance payments to “…be supported by a bill, invoice or evidence of payment…” (FAQ # 6). The program requirements (FAQ #s 10 & 11) limit utility assistance to 18 months. While the program allows for estimated payments in certain circumstances (FAQ # 38), the program requires excess assistance to be recovered or paid by the disbursing agency from non-federal sources if the recipient is found to be ineligible or the assistance in excess of program requirements.
Questioned Costs: None
Effect: Internal controls were not operating effectively during the period. Additionally, a change to the utility assistance controls reduced their effectiveness.
Cause: Internal controls over compliance were not appropriately designed, implemented, or operated to appropriately address the risk of noncompliance with the federal program requirements.
On January 1, 2023, DSHA implemented a program design change to allow up to $500 a month in utility assistance. This threshold was used to calculate the number of months of assistance being provided instead of using the actual utility costs for 18 months.
Recommendation: We recommend DSHA enhance its policies and procedures for processing rental assistance applications to ensure compliance with the federal program’s requirements.
Condition: The following conditions were found during audit testing of two ERA 2 quarterly reports:
1. DSHA procedures over the reporting did not include the documentation of the preparation and review of quarterly reports selected for testing.
2. Audit testing of a statistical sample of 15 cases processed during the year ended June 30, 2024, revealed an income calculation on a case which resulted in the incorrect calculation of Area Median Income (AMI) percentage. The AMI percentages calculated at the case level are utilized to support required demographic reporting.
3. Supporting documentation was not retained for information on the reports selected for testing.
4. A review of the reports selected for testing revealed the following:
a. The demographic information section of the ERA 2 report for the quarter ended December 30, 2023, was not completed.
b. Evidence could not be provided showing how administrative and housing stability service amounts expended and obligated were calculated.
A similar finding was noted during the audit of the year ended June 30, 2023. Refer to finding 2023-005.
Criteria: United States Department of the Treasury ERA Program Reporting Guidance version 3.2 was issued March 29, 2022, provides detailed reporting requirements.
2 CFR § 200.303 requires the implementation of effective internal controls:
“Internal controls requires the non-federal entity to 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.”
Questioned Costs: None
Effect: Reports required by the U.S. Treasury were not submitted timely, accurately, and supported by contemporaneously prepared documentation. Information required for the U.S. Treasury to calculate the required reallocations was not accurately reported on the quarterly reports submitted.
Cause: Internal controls over reporting were not appropriately designed, implemented, or operated. DSHA’s internal controls over the reporting process did not ensure information required information was captured.
Recommendation: We recommend DSHA enhance its policies and procedures for preparing and approving required reports prior to submission.
Condition: Reconciliation of the HAF client assistance expenditures for the year ended June 30, 2023, revealed approximately $290,000 of federal funds were held by a vendor contracted to process and disburse client assistance and were reported as federal expenditures. This amount had increased to $433,522 by October 26, 2023. The funds were offset against assistance payments processed by the vendor on November 14, 2023. During the operation of the program, the vendor received refunds of client assistance that were not timely remitted to DSHA or utilized to fund assistance.
A similar finding was noted during the audit of the year ended June 30, 2023. Refer to finding 2023-006.
Criteria: The Uniform Guidance Cost Principles requires DSHA to offset credits against program expenditures in 2 CFR 200.406(a):
Applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect (F&A) costs. Examples of such transactions are purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate.
Questioned Costs: $433,522
Effect: The funds held by the vendor were initially recorded as program costs.
Cause: DSHA was notified, by the vendor, that a credit was available to be applied to fund future assistance. The vendor did not apply the credit without DSHA’s explicit approval, which was not granted until November 14, 2023.
Recommendation: We recommend DSHA review the design and implementation of internal controls to address the identified weaknesses in internal control.
Condition: Audit control and compliance testing of a statistical sample of 40 cases processed during the year ended June 30, 2024, revealed the following:
Applicant income was calculated incorrectly for four cases sampled, that resulted in these applicants receiving more months of Future Payment Assistance than allowed by DSHA’s policy, resulting in overpayments totaling $21,062.
Applicant income was calculated incorrectly for 11 cases sampled, which did not result in these applicants receiving more assistance than allowed by DSHA’s policy. One of these applicants received fewer months of Future Payment Assistance than allowed by DSHA’s policy.
Compliance testing performed on a separate sample of 33 cases revealed applicant income was calculated incorrectly for two cases sampled. These two applicants received more months of Future Payment Assistance than allowed by DSHA’s policy resulting in overpayments totaling $9,397.
Analysis of assistance for the period of July 1, 2023, through June 30, 2024, identified two homeowners that received in excess of $50,000 of mortgage assistance resulting in overpayments of assistance totaling $863.
A similar finding was noted during the audit of the year ended June 30, 2023. Refer to finding 2023-008.
Context: BLS applied DSHA’s written policies and reviewed forms used in application processing. The homeowner income verification process supports the following program functions:
Determination of allowable homeowner eligibility for assistance.
Determination of allowable Future Payment Assistance (starting in November 2022).
Required reporting of assistance by income level.
Compliance with the HAF Program Earmarking requirements.
Criteria:
Eligibility Criteria - DSHA submitted a HAF Grantee Plan to U.S. Department of the Treasury on May 31, 2022. DSHA’s HAF Grantee Plan specifies the following process for the determination of homeowner income:
DSHA intends to accept written attestations from DE-HAF applicants to ascertain eligibility for the programs (100% of AMI or 150% of AMI depending on the program). DSHA does not anticipate allowing the use of geographic area or other criteria not linked directly to the homeowner’s individual determinants. In addition, while eligibility will be determined with a pass/fail income threshold, later in the application review process a more specific income verification process will be required to establish the amount of monthly mortgage obligation that will be affordable to the homeowner. This income verification process will need to rely on substantiated documentation.
This process is consistent with United States Department of the Treasury Homeowner Assistance Fund Guidance issued on June 12, 2023.
DSHA’s HAF program began to provide Future Payment Assistance on November 13, 2022, as follows:
Applicants between 31.01% - 50% HDTI can be eligible for ‘Reinstatement’ plus up to 3 months of mortgage payments.
Applicants with ‘No Income’ or a HDTI 50.01% and above can be eligible for ‘Reinstatement’ plus up to 6 months of mortgage payments. *
*If in addition to the assistance, applicants will be referred to a HUD-approved Housing Counseling Agency to assist with an action plan beyond the assistance.
Earmarking Criteria - The United States Department of the Treasury Homeowner Assistance Fund Guidance issued on June 12, 2023, requires that at least 60% of amounts, made available to each HAF participant, be used for qualified expenses that assist homeowners having incomes equal to, or less than, 100% of the area median income, or equal to or less than 100% of the median income for the United States, whichever is greater. Any amount not made available to homeowners that meet this income-targeting requirement must be prioritized for assistance to socially disadvantaged individuals, with funds remaining after such prioritization being made available for other eligible homeowners.
Reporting Criteria - Homeowner Assistance Fund quarterly reporting requires the submission of Application Data disaggregated by Area Median Income.
Maximum Allowed Assistance - DSHA’s program design limited assistance to $50,000 during the year end June 30, 2024.
Questioned Costs: $31,322 of overpayments.
Effect: Federal program assistance was overpaid. Applicant income determined by assistance calculation process was used for compliance with earmarking requirements and to support required reporting by applicant income level resulting in potential errors in program reports submitted to the U.S. Treasury.
Cause: Homeowner assistance application processing did not correctly determine verified homeowner income.
Recommendation: We recommend DSHA enhance its policies and procedures for processing HAF assistance applications to ensure accurate calculation of verified homeowner income.
Condition: Testing of DSHA’s December 31, 2023, and June 30, 2024 HAF quarterly reports revealed the reports submitted by DSHA reported the same amounts as expended and obligated, for Administrative Expenses and Services, and Counseling & Education. During the year ended June 30, 2024, DSHA entered various contracts for the operation of the program.
DSHA’s Annual Report had an extended due date of November 23, 2023, but was not filed until November 29, 2023. Evidence of an additional extension could not be provided.
A similar finding was noted during the audit of the year ended June 30, 2023. Refer to finding 2023-009.
Criteria: The United States Department of the Treasury Homeowner Assistance Fund Guidance on Participant Compliance and Reporting Responsibilities includes the following definitions:
Expenditure/Expended means any HAF assistance that has been spent by a HAF participant and/or Subrecipient. Please note, cumulative Expenditures cannot exceed cumulative Obligations.
Obligation/Obligated means an order placed for property and services, contracts and subawards made, and similar transactions that require payment (see 2 CFR § 200.1.). Obligated funds include funds that have been Expended.
Examples of obligated funds include: HAF funds that have been committed, pledged, or otherwise promised, in writing, to a specific individual or entity as part of a HAF program; HAF funds that have been set aside to cover obligations arising from loan guarantees; HAF funds that have been committed, pledged, or otherwise promised, in writing, as part of a transaction; and HAF funds that have been committed, pledged, or promised, in writing, for allowable administrative expenses (e.g., an executed contract for services).
The Homeowner Assistance Fund: Annual Report User Guide Issued October 14, 2022 (Updated October 13, 2023), requires the reporting of outcomes for assistance provided to Homeowners by Area Median Income and Socially Disadvantaged Individuals.
Questioned Costs: None
Effect: Reports required by the U.S. Treasury were not supported by contemporaneously prepared supporting documentation. Reports submitted to the U.S. Treasury did not include accurate reporting of program obligations. Reports required by the U.S. Treasury were not submitted timely.
Cause: The report preparation process did not consider executed contracts and agreements to be obligations.
Recommendation: We recommend DSHA enhance its policies and procedures for preparing and approving required reports prior to submission.
Condition: DSHA’s ERA program included various steps to monitor program disbursements for potential fraud. These monitoring processes were performed during the assistance determination process and by after-the-fact analysis and reviews. DSHA’s after-the-fact processes identified 17 households that potentially received $168,055 in fraudulent assistance during the program’s operation. As of June 30, 2024, the uncollected balance was $82,709. DSHA identified this potentially fraudulent assistance and recovered a portion but did not further pursue resolution of the matter.
Criteria: The Emergency Rental Assistance program FAQ specifically requires DSHA “…to investigate and address potential instances of fraud or the misuse of funds that they become aware of.”
Questioned Costs: $82,709
Effect: Assistance was potentially provided to ineligible applicants due to fraudulent submissions.
Cause: Internal controls over eligibility were not able to prevent or detect and correct potentially fraudulent behavior by applicants.
Recommendation: We recommend DSHA further investigate, and report fraud or potential fraud as required by the CFR and program guidelines.