Audit 36600

2022-001 Significant Deficiency in Internal Control and on Compliance with Reporting and Special Tests and Provisions Identification of federal program: 21.023 Emergency Rental Assistance Program Criteria or specific requirement: 21.023 Part 4 Compliance Supplement: Quarterly Reports: All ERA grantees must submit quarterly reports with reporting periods of one calendar quarter and several cumulative fields covering all activity from the date of 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 CARES Act, as amended and interpreted in Treasury?s reporting and compliance guidance on Treasury.gov. ERA Funds Reallocation: Auditors should confirm that financial information certified by grantees used by Treasury to make reallocation determinations is accurate. Auditors should confirm the amounts reported as expended and obligated accurately capture the grantee?s housing activity at the time of submission, as reflected in a grantee?s award and/or financial systems. Addendum to Reallocation Guidance for Tribal Governments June 1, 2022: Treasury will reallocate ERA1 funds for Tribal governments after the Q2 2022 reporting period ending on June 30, 2022. Teasury will measure ERA1 expenditures (including prior quarter?s expenditures) and obligations based on the Q2 2022 reporting, which is due on July 15, 2022. Condition: The Native Village submitted the required Q2 2022 report and erroneously reported the full balance of the award as obligated at that time, however there are no records supporting that the full balance was obligated as defined by Treasury. Also, the Native Village submitted the final report and erroneously reported administrative expenses greater than the 10% allowed administrative expense requirement. Cause: The Native Village had difficulty with the reporting portal provided by Treasury. On the Q2 report, NVFY reported the full balance of ERA funds as obligated; it was the intension of the Native Village to spend all of the funds received under this program, however these funds did not meet Treasury?s definition of obligated. On the final report the Native Village reported unobligated funds appropriately and is in progress of returning the unobligated balance to Treasury. Also, the reporting portal did not allow the Native Village to report housing stability costs, and therefore, in order to meet the reporting deadline, the Native Village reported housing stability costs and administrative costs within the same line item on the reporting portal, so it was reported that Native Village spent more than 10% on administrative costs, however that is not the case. Effect or potential effect: The reporting submitted to Treasury didn?t agree to the Native Village accounting records Questioned Costs: None Context: Four quarterly reports were due during the fiscal year; the auditor requested two of the reports for testing (Quarters ended June 30, 2022, and September 30, 2022, respectively). Of the two tested, the Q2 2022 report inaccurately reflected the Native Villages obligated funds and the Q3 2022 Final Report inaccurately reported the Native Villages administrative costs. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that as a part of the Native Village?s internal control structure over compliance with reporting requirements to establish monitoring procedures to ensure federal reporting is performed accurately. Views of Responsible Officials: See Corrective Action Plan

2022-001 Significant Deficiency in Internal Control and on Compliance with Reporting and Special Tests and Provisions Identification of federal program: 21.023 Emergency Rental Assistance Program Criteria or specific requirement: 21.023 Part 4 Compliance Supplement: Quarterly Reports: All ERA grantees must submit quarterly reports with reporting periods of one calendar quarter and several cumulative fields covering all activity from the date of 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 CARES Act, as amended and interpreted in Treasury?s reporting and compliance guidance on Treasury.gov. ERA Funds Reallocation: Auditors should confirm that financial information certified by grantees used by Treasury to make reallocation determinations is accurate. Auditors should confirm the amounts reported as expended and obligated accurately capture the grantee?s housing activity at the time of submission, as reflected in a grantee?s award and/or financial systems. Addendum to Reallocation Guidance for Tribal Governments June 1, 2022: Treasury will reallocate ERA1 funds for Tribal governments after the Q2 2022 reporting period ending on June 30, 2022. Teasury will measure ERA1 expenditures (including prior quarter?s expenditures) and obligations based on the Q2 2022 reporting, which is due on July 15, 2022. Condition: The Native Village submitted the required Q2 2022 report and erroneously reported the full balance of the award as obligated at that time, however there are no records supporting that the full balance was obligated as defined by Treasury. Also, the Native Village submitted the final report and erroneously reported administrative expenses greater than the 10% allowed administrative expense requirement. Cause: The Native Village had difficulty with the reporting portal provided by Treasury. On the Q2 report, NVFY reported the full balance of ERA funds as obligated; it was the intension of the Native Village to spend all of the funds received under this program, however these funds did not meet Treasury?s definition of obligated. On the final report the Native Village reported unobligated funds appropriately and is in progress of returning the unobligated balance to Treasury. Also, the reporting portal did not allow the Native Village to report housing stability costs, and therefore, in order to meet the reporting deadline, the Native Village reported housing stability costs and administrative costs within the same line item on the reporting portal, so it was reported that Native Village spent more than 10% on administrative costs, however that is not the case. Effect or potential effect: The reporting submitted to Treasury didn?t agree to the Native Village accounting records Questioned Costs: None Context: Four quarterly reports were due during the fiscal year; the auditor requested two of the reports for testing (Quarters ended June 30, 2022, and September 30, 2022, respectively). Of the two tested, the Q2 2022 report inaccurately reflected the Native Villages obligated funds and the Q3 2022 Final Report inaccurately reported the Native Villages administrative costs. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that as a part of the Native Village?s internal control structure over compliance with reporting requirements to establish monitoring procedures to ensure federal reporting is performed accurately. Views of Responsible Officials: See Corrective Action Plan