Audit 56435

Condition: Eligibility for ERAP1 required that individuals self-attest that they had a need for rental or utility assistance under the ERAP program. Eligibility is defined in the OMB's compliance supplement and guidance. Reason Improvement Needed: Eligibility is a key component of the ability of any Federal agency or funding recipient to disburse funds under the COVID-19 funding. The Center needs to ensure that eligibility is monitored and thoroughly checked to ensure individuals who are not eligible do not receive funding. Cause of Condition: The Center paid out funds as it was required by current guidance. ERAP1 was to be paid out on self-attestation standards allowing the affected renters the ability to "self-certify" that they were in need of the rental assistance and other utility assistance in order to gain access to the funds. When ERAP2 was administered, the guidance changed to require the Center to request and validate multiple types of support to ensure that the funds were necessary for the individual. Effect of Condition: Self attestation leaves the onerous of being truthful on the individual receiving the funds and takes the ability to deny one's funding for fraudulent reasons out of the hands of the Center. Perspective Information: We don't find this to be a systemic issue. The Center has complied with all types of eligibility testing requirements each year for the ERAP 1 and ERAP2 funding. The Center only identified the fraud during FY21 in the ERAP1 funding when the ERAP2 guidelines changed and some of the same individuals applied for the funding again. Identification of Repeat Findings: This is NOT a repeat finding from the prior year. Recommendation: Our recommendation is that the Center continue to be diligent on its disbursement of the funds and ensure that it continues to follow all of the guidelines and guidance posted by the OMB via the compliance supplements and federal guidelines. Benefits of Recommended Action: By following the recommendation, for the remainder of the ERAP1 and ERAP 2 time frame, the Center will ensure it remains in compliance. Client Response: The Center has turned over the names and amounts of funds that were fraudulently gained from the ERAP1 program to the pass-through entity by which it received the original funding. The pass-through entity is the prosecuting entity who will determine how to properly move forward with the fraud claims. The Center has fulfilled its duty to report any fraud identified in the program.

Condition: Eligibility for ERAP1 required that individuals self-attest that they had a need for rental or utility assistance under the ERAP program. Eligibility is defined in the OMB's compliance supplement and guidance. Reason Improvement Needed: Eligibility is a key component of the ability of any Federal agency or funding recipient to disburse funds under the COVID-19 funding. The Center needs to ensure that eligibility is monitored and thoroughly checked to ensure individuals who are not eligible do not receive funding. Cause of Condition: The Center paid out funds as it was required by current guidance. ERAP1 was to be paid out on self-attestation standards allowing the affected renters the ability to "self-certify" that they were in need of the rental assistance and other utility assistance in order to gain access to the funds. When ERAP2 was administered, the guidance changed to require the Center to request and validate multiple types of support to ensure that the funds were necessary for the individual. Effect of Condition: Self attestation leaves the onerous of being truthful on the individual receiving the funds and takes the ability to deny one's funding for fraudulent reasons out of the hands of the Center. Perspective Information: We don't find this to be a systemic issue. The Center has complied with all types of eligibility testing requirements each year for the ERAP 1 and ERAP2 funding. The Center only identified the fraud during FY21 in the ERAP1 funding when the ERAP2 guidelines changed and some of the same individuals applied for the funding again. Identification of Repeat Findings: This is NOT a repeat finding from the prior year. Recommendation: Our recommendation is that the Center continue to be diligent on its disbursement of the funds and ensure that it continues to follow all of the guidelines and guidance posted by the OMB via the compliance supplements and federal guidelines. Benefits of Recommended Action: By following the recommendation, for the remainder of the ERAP1 and ERAP 2 time frame, the Center will ensure it remains in compliance. Client Response: The Center has turned over the names and amounts of funds that were fraudulently gained from the ERAP1 program to the pass-through entity by which it received the original funding. The pass-through entity is the prosecuting entity who will determine how to properly move forward with the fraud claims. The Center has fulfilled its duty to report any fraud identified in the program.