Assistance Listing Number, Federal Agency, and Program Name - 21.023, U.S. Department of the Treasury, COVID-19 - Emergency Rental Assistance Program Federal Award Identification Number and Year - ERA0415, 2022 Pass through Entity - Michigan State Housing Development Authority Finding Type - Significant deficiency Repeat Finding - Yes Prior Year Refence Number - 2021-001 Criteria -Per 2 CFR 200.303, an entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The federal award agreement includes specific allowable costs calculated in accordance with the U.S. Treasury guidance. Condition - Controls in place did not identify an inaccurate calculation of assistance. Questioned Costs - $250 Identification of How Questioned Costs Were Computed - Questioned costs were computed based on the difference between the rental assistance payment disbursed and the rental assistance payment calculated in accordance with the U.S. Treasury guidance. Context - Out of a sample of 60 assistance case numbers selected for allowability testing, 1 sample was not properly calculated in accordance with the U.S. Treasury guidance. The inaccurate calculation caused an overpayment in rental assistance charged to the program. A demand for repayment was issued for the $250 overpayment. Cause and Effect - While the Organization had procedures in place to review the rental assistance calculations, management's review did not prevent an inaccurate assistance payment. As a result, the Organization disbursed an amount that was not calculated in accordance with the U.S. Treasury guidance. Recommendation - We recommend the Organization review its procedures and controls to ensure calcuations of eligible expenses are performed accurately. Views of Responsible Officials and Corrective Action Plan - While all cases processed by Case Managers were quality reviewed by a team from CLA (an outsourced professional services firm specializing in grants management), documentation provided by tenants and/or landlords may not always have been clear and therefore interpreted differently by each reviewing party. Throughout the course of the grant, we continued to meet twice weekly in an effort to keep all of the Case Managers up to speed with the regularly changing guidance and documentation requirements. The corrective action plan in response to Finding 2021-001 was implemented on September 23, 2022; and therefore the fiscal year ended June 30, 2022 was complete before implementation of the corrective action plan, which is as follows: Case Managers, Quality Review and Agency Managers can see supporting documentation and review cases in real time. All cases are processed by Case Managers, who consult with Agency Managers on questions, and 100 percent of cases are quality reviewed by a team from CLA prior to processing payment. As Heart of West Michigan United Way receives MSHDA written guidance updates, we continue to hold twice-weekly meetings with CERA Agency Managers to discuss the frequent changes to the MSHDA guidance in order to gain a full understanding of the program requirements and regulations. Information is then disseminated to Case Managers. We will continue to hold regular trainings for CERA Case Managers to ensure consistency in approach and understanding of required documentation and proper assistance calculation. CLA continues to conduct a quality review check of 100 percent of applications to enhance internal controls and oversight. Additionally, the CERA Program Manager completes random checks of assistance calculations and payments.
Assistance Listing Number, Federal Agency, and Program Name - 21.023, U.S. Department of the Treasury, COVID-19 - Emergency Rental Assistance Program Federal Award Identification Number and Year - ERA0415, 2022 Pass through Entity - Michigan State Housing Development Authority Finding Type - Significant deficiency Repeat Finding - Yes Prior Year Refence Number - 2021-001 Criteria -Per 2 CFR 200.303, an entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The federal award agreement includes specific allowable costs calculated in accordance with the U.S. Treasury guidance. Condition - Controls in place did not identify an inaccurate calculation of assistance. Questioned Costs - $250 Identification of How Questioned Costs Were Computed - Questioned costs were computed based on the difference between the rental assistance payment disbursed and the rental assistance payment calculated in accordance with the U.S. Treasury guidance. Context - Out of a sample of 60 assistance case numbers selected for allowability testing, 1 sample was not properly calculated in accordance with the U.S. Treasury guidance. The inaccurate calculation caused an overpayment in rental assistance charged to the program. A demand for repayment was issued for the $250 overpayment. Cause and Effect - While the Organization had procedures in place to review the rental assistance calculations, management's review did not prevent an inaccurate assistance payment. As a result, the Organization disbursed an amount that was not calculated in accordance with the U.S. Treasury guidance. Recommendation - We recommend the Organization review its procedures and controls to ensure calcuations of eligible expenses are performed accurately. Views of Responsible Officials and Corrective Action Plan - While all cases processed by Case Managers were quality reviewed by a team from CLA (an outsourced professional services firm specializing in grants management), documentation provided by tenants and/or landlords may not always have been clear and therefore interpreted differently by each reviewing party. Throughout the course of the grant, we continued to meet twice weekly in an effort to keep all of the Case Managers up to speed with the regularly changing guidance and documentation requirements. The corrective action plan in response to Finding 2021-001 was implemented on September 23, 2022; and therefore the fiscal year ended June 30, 2022 was complete before implementation of the corrective action plan, which is as follows: Case Managers, Quality Review and Agency Managers can see supporting documentation and review cases in real time. All cases are processed by Case Managers, who consult with Agency Managers on questions, and 100 percent of cases are quality reviewed by a team from CLA prior to processing payment. As Heart of West Michigan United Way receives MSHDA written guidance updates, we continue to hold twice-weekly meetings with CERA Agency Managers to discuss the frequent changes to the MSHDA guidance in order to gain a full understanding of the program requirements and regulations. Information is then disseminated to Case Managers. We will continue to hold regular trainings for CERA Case Managers to ensure consistency in approach and understanding of required documentation and proper assistance calculation. CLA continues to conduct a quality review check of 100 percent of applications to enhance internal controls and oversight. Additionally, the CERA Program Manager completes random checks of assistance calculations and payments.
Assistance Listing Number, Federal Agency, and Program Name - 21.023, U.S. Department of the Treasury, COVID-19 - Emergency Rental Assistance Program Federal Award Identification Number and Year - ERA0415, 2022 Pass through Entity - Michigan State Housing Development Authority Finding Type - Significant deficiency Repeat Finding - Yes Prior Year Refence Number - 2021-001 Criteria -Per 2 CFR 200.303, an entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The federal award agreement includes specific allowable costs calculated in accordance with the U.S. Treasury guidance. Condition - Controls in place did not identify an inaccurate calculation of assistance. Questioned Costs - $250 Identification of How Questioned Costs Were Computed - Questioned costs were computed based on the difference between the rental assistance payment disbursed and the rental assistance payment calculated in accordance with the U.S. Treasury guidance. Context - Out of a sample of 60 assistance case numbers selected for allowability testing, 1 sample was not properly calculated in accordance with the U.S. Treasury guidance. The inaccurate calculation caused an overpayment in rental assistance charged to the program. A demand for repayment was issued for the $250 overpayment. Cause and Effect - While the Organization had procedures in place to review the rental assistance calculations, management's review did not prevent an inaccurate assistance payment. As a result, the Organization disbursed an amount that was not calculated in accordance with the U.S. Treasury guidance. Recommendation - We recommend the Organization review its procedures and controls to ensure calcuations of eligible expenses are performed accurately. Views of Responsible Officials and Corrective Action Plan - While all cases processed by Case Managers were quality reviewed by a team from CLA (an outsourced professional services firm specializing in grants management), documentation provided by tenants and/or landlords may not always have been clear and therefore interpreted differently by each reviewing party. Throughout the course of the grant, we continued to meet twice weekly in an effort to keep all of the Case Managers up to speed with the regularly changing guidance and documentation requirements. The corrective action plan in response to Finding 2021-001 was implemented on September 23, 2022; and therefore the fiscal year ended June 30, 2022 was complete before implementation of the corrective action plan, which is as follows: Case Managers, Quality Review and Agency Managers can see supporting documentation and review cases in real time. All cases are processed by Case Managers, who consult with Agency Managers on questions, and 100 percent of cases are quality reviewed by a team from CLA prior to processing payment. As Heart of West Michigan United Way receives MSHDA written guidance updates, we continue to hold twice-weekly meetings with CERA Agency Managers to discuss the frequent changes to the MSHDA guidance in order to gain a full understanding of the program requirements and regulations. Information is then disseminated to Case Managers. We will continue to hold regular trainings for CERA Case Managers to ensure consistency in approach and understanding of required documentation and proper assistance calculation. CLA continues to conduct a quality review check of 100 percent of applications to enhance internal controls and oversight. Additionally, the CERA Program Manager completes random checks of assistance calculations and payments.
Assistance Listing Number, Federal Agency, and Program Name - 21.023, U.S. Department of the Treasury, COVID-19 - Emergency Rental Assistance Program Federal Award Identification Number and Year - ERA0415, 2022 Pass through Entity - Michigan State Housing Development Authority Finding Type - Significant deficiency Repeat Finding - Yes Prior Year Refence Number - 2021-001 Criteria -Per 2 CFR 200.303, an entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The federal award agreement includes specific allowable costs calculated in accordance with the U.S. Treasury guidance. Condition - Controls in place did not identify an inaccurate calculation of assistance. Questioned Costs - $250 Identification of How Questioned Costs Were Computed - Questioned costs were computed based on the difference between the rental assistance payment disbursed and the rental assistance payment calculated in accordance with the U.S. Treasury guidance. Context - Out of a sample of 60 assistance case numbers selected for allowability testing, 1 sample was not properly calculated in accordance with the U.S. Treasury guidance. The inaccurate calculation caused an overpayment in rental assistance charged to the program. A demand for repayment was issued for the $250 overpayment. Cause and Effect - While the Organization had procedures in place to review the rental assistance calculations, management's review did not prevent an inaccurate assistance payment. As a result, the Organization disbursed an amount that was not calculated in accordance with the U.S. Treasury guidance. Recommendation - We recommend the Organization review its procedures and controls to ensure calcuations of eligible expenses are performed accurately. Views of Responsible Officials and Corrective Action Plan - While all cases processed by Case Managers were quality reviewed by a team from CLA (an outsourced professional services firm specializing in grants management), documentation provided by tenants and/or landlords may not always have been clear and therefore interpreted differently by each reviewing party. Throughout the course of the grant, we continued to meet twice weekly in an effort to keep all of the Case Managers up to speed with the regularly changing guidance and documentation requirements. The corrective action plan in response to Finding 2021-001 was implemented on September 23, 2022; and therefore the fiscal year ended June 30, 2022 was complete before implementation of the corrective action plan, which is as follows: Case Managers, Quality Review and Agency Managers can see supporting documentation and review cases in real time. All cases are processed by Case Managers, who consult with Agency Managers on questions, and 100 percent of cases are quality reviewed by a team from CLA prior to processing payment. As Heart of West Michigan United Way receives MSHDA written guidance updates, we continue to hold twice-weekly meetings with CERA Agency Managers to discuss the frequent changes to the MSHDA guidance in order to gain a full understanding of the program requirements and regulations. Information is then disseminated to Case Managers. We will continue to hold regular trainings for CERA Case Managers to ensure consistency in approach and understanding of required documentation and proper assistance calculation. CLA continues to conduct a quality review check of 100 percent of applications to enhance internal controls and oversight. Additionally, the CERA Program Manager completes random checks of assistance calculations and payments.