Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.