Corrective Action Plans

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Federal Perkins Loan Program Third‐Party Servicer Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Recommendation: We recommend reviewing procedures and requirements regarding Perkins third party service providers and...
Federal Perkins Loan Program Third‐Party Servicer Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Recommendation: We recommend reviewing procedures and requirements regarding Perkins third party service providers and ensure compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university is in the process of implementing policies and procedures regarding reconciliations for Perkins loan services managed by a 3rd party supplier. Name(s) of the contact person(s) responsible for corrective action: Danyel Tolbert ‐Bursar Planned completion date for corrective action plan: June 30,2025
Finding Number: 2023-006 Finding Title: Eligibility Name of Contact Person Responsible for Corrective Action: Patti Hart – Financial Assistance Supervisor II in conjunction with Kevin DeVriendt – Auditor-Treasurer Corrective Action Planned: This topic will be a standing agenda item on the Public He...
Finding Number: 2023-006 Finding Title: Eligibility Name of Contact Person Responsible for Corrective Action: Patti Hart – Financial Assistance Supervisor II in conjunction with Kevin DeVriendt – Auditor-Treasurer Corrective Action Planned: This topic will be a standing agenda item on the Public Health and Human Services Income Maintenance unit meeting agendas, being reviewed at least monthly to ensure compliance. Supervisor Hart will review five Medical Assistance (MA) applications or renewals per month, to ensure MAXIS has been updated with the correct asset and income eligibility information. Anticipated Completion Date: May 15, 2025
2023-004 Public Housing Waiting List Tenant Selection – RF (2022-006) In October of 2022 there was no waiting list in the Housing Management Software, there was not a handwritten waitlist that could be located. Staff entered all applications that were located into the software by date and time and w...
2023-004 Public Housing Waiting List Tenant Selection – RF (2022-006) In October of 2022 there was no waiting list in the Housing Management Software, there was not a handwritten waitlist that could be located. Staff entered all applications that were located into the software by date and time and with preferences that are in the out-of-date Admissions and Occupancy Policy and Administrative Plan. Documentation was submitted to the San Antonio Field Office in September of 2023 to show the waitlist and the families that have been selected in order of the waitlist or removed at the request of the family.
CORRECTIVE ACTION PLAN Name of the Project: Baten Arms Apartments FHA/CONTACT NO. 114-11227 Audit Firm: M Group, LLP Audit Period: The year ended June 30, 2023 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding ou...
CORRECTIVE ACTION PLAN Name of the Project: Baten Arms Apartments FHA/CONTACT NO. 114-11227 Audit Firm: M Group, LLP Audit Period: The year ended June 30, 2023 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING #2023-003: Section 8 Housing Assistance Payments Program, CFDA: 14.195 and Mortgage Insurance Section 223(f) Insured Loan, CFDA:14.155 CORRECTIVE ACTION TO BE COMPLETED: The Corporation will review and monitor documentation procedures to ensure compliance regarding cash disbursements. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Stewart Grounds.
View Audit 359650 Questioned Costs: $1
Contact Person Derek Johnson, Executive Director Corrective Action Plan The Authority will review its policies and procedures over program compliance requirements and continue to provide occupancy training to staff to prevent future exceptions. Planned Completion Date for CAP December 31, 2024
Contact Person Derek Johnson, Executive Director Corrective Action Plan The Authority will review its policies and procedures over program compliance requirements and continue to provide occupancy training to staff to prevent future exceptions. Planned Completion Date for CAP December 31, 2024
Finding 2023-002: Eligibility Documentation Management’s Response Mid Michigan CAA acknowledges the audit finding regarding the documentation of diaper distribution to income-eligible participants under the Temporary Assistance for Needy Families (TANF) program. We appreciate the opportunity to pro...
Finding 2023-002: Eligibility Documentation Management’s Response Mid Michigan CAA acknowledges the audit finding regarding the documentation of diaper distribution to income-eligible participants under the Temporary Assistance for Needy Families (TANF) program. We appreciate the opportunity to provide clarification and outline corrective actions. The Diaper Bank Program operated under the oversight of the Michigan Department of Health and Human Services (MDHHS), which conducted regular monitoring and did not identify any concerns related to eligibility or distribution practices during their reviews. In accordance with program requirements, all participating diaper banks were pre-existing programs with access to alternative funding sources. These sources were explicitly intended to support the distribution of diapers to households that did not meet TANF income eligibility criteria. While Mid Michigan CAA did not maintain centralized documentation of the specific funding source used for each distribution, it was understood and communicated to partner entities that TANF-funded diapers were to be reserved for eligible households only. To strengthen internal controls and ensure full compliance with TANF requirements, Mid Michigan CAA has implemented the following measures: 1. Development of a standardized tracking system to document only diapers distributed to each household using TANF funds. 2. Training for all partner entities on eligibility verification procedures and documentation requirements. 3. Periodic internal audits to verify compliance and ensure accurate recordkeeping. Contact Person Responsible for Corrective Action: Eva Rohlman, Outreach & Opportunities Director Anticipated Completion Date: 10/1/2024
As of 2/17/2025 OKVU added sub-coding to the general ledger to identify administrative labor costs under 7000 – Salaries & wages, 7100 – Fringe benefits and 7200 – Payroll taxes bases on direct allocations provided to the payroll system. This information will be provided by report from the payroll s...
As of 2/17/2025 OKVU added sub-coding to the general ledger to identify administrative labor costs under 7000 – Salaries & wages, 7100 – Fringe benefits and 7200 – Payroll taxes bases on direct allocations provided to the payroll system. This information will be provided by report from the payroll system and added via journal entry to the GL.
As of 12/06/2024 OKVU implemented the addition of the Asset Calculation Worksheet to the veteran case file. To ensure compliance the requirement was also added to the discharge file QC checklist and the SSVF policy and procedure manual updated. As of 12/11/2024 all case manager staff were provided t...
As of 12/06/2024 OKVU implemented the addition of the Asset Calculation Worksheet to the veteran case file. To ensure compliance the requirement was also added to the discharge file QC checklist and the SSVF policy and procedure manual updated. As of 12/11/2024 all case manager staff were provided training.
N/A - The Healthy Start Program transitioned to another local non-profit October 31, 2023. The Council will no longer have direct control over their corrective action plan.
N/A - The Healthy Start Program transitioned to another local non-profit October 31, 2023. The Council will no longer have direct control over their corrective action plan.
Auditor's Recommendation: The auditor recommends the Organization enhance the design of its control activities and procedures over the reporting of consumer eligibility dates to ensure that date of eligibility agree between the ILS and DRS systems. Management’s Response: The LIFE Inc. staff have re...
Auditor's Recommendation: The auditor recommends the Organization enhance the design of its control activities and procedures over the reporting of consumer eligibility dates to ensure that date of eligibility agree between the ILS and DRS systems. Management’s Response: The LIFE Inc. staff have received training on new measures to ensure that the eligibility dates in the databases are consistent. When new Consumers request assistance through the Purchased Services Program, their intake appointments are scheduled simultaneously with those for the Base Grant Services. This coordination helps guarantee that the dates in both databases match. Due date of completion: May 31, 2025 Responsible Official: Program Director, Lidia Taylor
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Federal Assistance Listing Numbers: 14.871 and 14.879 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance M...
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Federal Assistance Listing Numbers: 14.871 and 14.879 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203(Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that new move-ins were selected from the wait list in an order that is in accordance with the Authority’s policy. Context: Thirty-two (32) names were selected from the new move-in list and those names were to be traced to the waiting list to verify new move-ins were chosen in an order that was in accordance with the Authority’s policy. It was determined that six (6) out of thirty-two (32) new move-ins selected could not be traced with any certainty back to the Authority's waiting list. Known Questioned Costs: 14.871 - Section 8 Housing Choice Vouchers - $35,098 14.879 - Mainstream Vouchers - $13,796 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selections from the waiting list. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers and Mainstream Vouchers programs are in material non-compliance with the special tests and provisions type of compliance related to selections from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Shannon Koenig, executive director and CEO, is responsible for implementing this corrective action by December 31, 2024.
View Audit 358812 Questioned Costs: $1
Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871, 14.879, and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Ma...
Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871, 14.879, and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility. Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 6,531 units. Of a sample size of seventy-seven (77) tenant files, the following was noted: - Section 214 citizen declaration form missing in 15 files - HUD 9887 consent to release information form missing in 2 files - Original application missing in 1 file - Annual inspection missing in 1 file - Lead based paint form missing in 4 files - Verification of income missing in 6 files Our sample size is statistically valid. Known Questioned Costs: 14.871 - Section 8 Housing Choice Vouchers - $36,728 14.879 - Mainstream Vouchers - $13,028 14.EHV - Emergency Housing Vouchers - $1,272 Cause: There is a material weakness in the Housing Voucher Cluster in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor, and will make the several changes to its inspection process to ensure enforcement of Housing Quality Standards (or any subsequent replacement). Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Shannon Koenig, executive director and CEO, is responsible for implementing this corrective action by December 31, 2024.
View Audit 358812 Questioned Costs: $1
CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...
CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-001 Responsible Party Name: Gina Rice Position: Director of Accounting Telephone Number: 816-238-4511 ext 131 Federal Agency U.S. Department of Agriculture Federal Program Emergency Food Assistance Program (Food Commodities) Compliance Requirements E - Eligibility Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will establish a process to ensure required eligibility documentation is maintained in accordance with federal program requirements which will include periodic monitoring and review performed by personnel not directly involved with program administration. Anticipated Completion Date June 2025
2023-004 Activities Allowed or Unallowed – Interprogram Activity Public and Indian Housing – CFDA Number 14.850 Other Matters, Questioned Costs Condition: The Authority has loaned monies from the Public and Indian Housing Program to the COCC. As of September 30, 2023 these loans totaled $349,352. ...
2023-004 Activities Allowed or Unallowed – Interprogram Activity Public and Indian Housing – CFDA Number 14.850 Other Matters, Questioned Costs Condition: The Authority has loaned monies from the Public and Indian Housing Program to the COCC. As of September 30, 2023 these loans totaled $349,352. Recommendation: The Authority should develop a plan based on budgeting and monitoring of COCC expenses to have the ability to reimburse funds to the Public and Indian Housing Program. Action Taken: To restore financial integrity and ensure proper use of COCC funds, the Authority will take the following actions: 1. COCC Optimization and Budget Reform: Develop and implement a proper, balanced COCC budget that reflects actual operating costs and allocates shared services appropriately. Establish budget accountability protocols, including monthly budget-to-actual reviews and variance reporting to the CFO, CEO, and Board. 2. Training and Capacity Building: Provide training for finance staff on COCC operations, HUD’s Asset Management model, and best practices for cost allocation and shared services. Engage external consultants to support financial modeling and long-term sustainability planning for RAD and LIHTC properties. 3. Shared Services Agreement: Formalize a Consulting and Shared Services Agreement to ensure that COCC services are appropriately billed and reimbursed by other programs. Monitor inter-program transactions to ensure compliance with HUD’s financial management requirements. 4. Salary Allocation and Cost Tracking: Conduct a salary allocation study to ensure that staff time is distributed adequately across programs. Implement time-tracking tools and cost allocation methodologies that align with HUD guidance and OMB Uniform Guidance. Effective Date: June 3, 2025 Contact Information Dr. Michael C. Threatt, Chief Executive Officer Sanford Housing Authority 317 Chatham Street Sanford, North Carolina 27330 (919) 776-7655
View Audit 358177 Questioned Costs: $1
Incorrect Pell Calculations Planned Corrective Action: A process will be implemented to verify Pell is correctly awarded before disbursements are made. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25
Incorrect Pell Calculations Planned Corrective Action: A process will be implemented to verify Pell is correctly awarded before disbursements are made. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25
View Audit 358096 Questioned Costs: $1
Enrollment Reporting to NSLDS Planned Corrective Action: A process will be created to ensure enrollment is reported timely and accurately. Spot checks of NSLDS will be performed on enrollment status throughout the year. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for B...
Enrollment Reporting to NSLDS Planned Corrective Action: A process will be created to ensure enrollment is reported timely and accurately. Spot checks of NSLDS will be performed on enrollment status throughout the year. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25
ISIR Comment Resolution Planned Corrective Action: All ISIR comment codes will be resolved before disbursement of federal aid to students. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25
ISIR Comment Resolution Planned Corrective Action: All ISIR comment codes will be resolved before disbursement of federal aid to students. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25
Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09...
Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25
Finding 561616 (2023-006)
Significant Deficiency 2023
Finding Number: 2023-006 Finding Title: Reporting – DHS Social Service Fund (DHS-2556) Program: 93.658 Foster Care – Title IV-E Name of Contact Person Responsible for Corrective Action: Janelle White – Controller for Ramsey County’s Health & Wellness Service Team Enrique Rivera – Fiscal Services ...
Finding Number: 2023-006 Finding Title: Reporting – DHS Social Service Fund (DHS-2556) Program: 93.658 Foster Care – Title IV-E Name of Contact Person Responsible for Corrective Action: Janelle White – Controller for Ramsey County’s Health & Wellness Service Team Enrique Rivera – Fiscal Services Manager for Ramsey County’s Health & Wellness Service Team Corrective Action Planned: Starting in the third quarter of 2024, Ramsey County instituted an additional verification step in the review process to support the determination of accurate cost pool categorization of reimbursable costs for the Random Moment Time Study Reports cost reports. The additional step will be to confirm that on the Summary Tab of the Quarterly Payroll file, the cost codes lines are in sequential order and that the corresponding expense totals match the cost code. The Senior Accountant will do the first review of this step, and the Fiscal Manager will complete the second review. The error on the 2nd quarter 2023 report was remedied and resubmitted in the 2nd quarter of 2024. Anticipated Completion Date: July of 2024 when the 2nd quarter DHS-2556 and DHS 2550 are due to be complete and finalized.
Finding 561615 (2023-004)
Material Weakness 2023
Finding Number: 2023-004 Finding Title: Eligibility Program: 21.023 COVID-19 – Emergency Rental Assistance Program Name of Contact Person Responsible for Corrective Action: Daniel Rahkola, Division Director Finance Corrective Action Planned: Staff will be retrained on the procedures to ensure compl...
Finding Number: 2023-004 Finding Title: Eligibility Program: 21.023 COVID-19 – Emergency Rental Assistance Program Name of Contact Person Responsible for Corrective Action: Daniel Rahkola, Division Director Finance Corrective Action Planned: Staff will be retrained on the procedures to ensure compliance with the needed standards. Anticipated Completion Date: June 30, 2025
View Audit 357223 Questioned Costs: $1
The auditors reviewed 6 tenant files for initial admission criteria being met, such as Income calculations. Of the 6 files, 5 did not contain supporting documentation of how the income was calculated. Again, those staff are not present coming into FY2024. Of the 6 files reviewed, 3 also did not h...
The auditors reviewed 6 tenant files for initial admission criteria being met, such as Income calculations. Of the 6 files, 5 did not contain supporting documentation of how the income was calculated. Again, those staff are not present coming into FY2024. Of the 6 files reviewed, 3 also did not have 50058’s in the tenant file. And all 6 files could not be traced back to the waitlist to determine proper entrance to the program. In response to the tracking of the waitlist not being tracked on new admissions, there have not been any new HCV vouchers issued from the waitlist since the end of FY2022. RHA has an over utilization of voucher budget authority and has not issued new vouchers from that waiting list nor has RHA opened that waiting list up. RHA administration does not expect to open this waiting list in FY2024 nor FY2025. At the tail end of FY2023, RHA sent the PBV waiting lists over to the contracted third-party management company to track for RHA. Currently, that third-party management company is Allied Residential Management. Halfway through FY2024, RHA converted over to a different Housing Software which has better tracking reports than the prior software. Again, RHA has hired new staff and removed old staff that did not want to learn correct compliance procedures with the HCV department. RHA has a strong team coming into FY2025 now. FY2024 had staff in/out until we found good staff that wanted to learn and retain them.
Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the 40 tenant files sampled by the auditors, 29 files did not have correct utility allowances calculated; 9 files had 50058’s that did...
Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the 40 tenant files sampled by the auditors, 29 files did not have correct utility allowances calculated; 9 files had 50058’s that did not agree with the HAP payments being paid to the landlords and 22 files had rents that did not fall between 90% and 110% of the HUD FMR for the areas. Staff have been replaced and there are no original HCV staff left that were at RHA when the new CEO took over on March 1, 2023. Staff are consistently being trained every week for a minimum of 1 hour a week for 52 weeks out of the year. An HCV Director has been added to supervise the HCV Staff and audits of the files are being completed by the Director of Housing along with the CEO. These issues should be limited and not commonly found by Auditors during future audits.
Prior RHA administrative staff were not getting the PHA’s Single Audit completed nor submitted by the deadline. RHA was 3 years behind when the new CEO took over on March 31, 2023. FY2020, FY2021 and FY2022 were not completed and submitted. By the time that these three were caught up, completed...
Prior RHA administrative staff were not getting the PHA’s Single Audit completed nor submitted by the deadline. RHA was 3 years behind when the new CEO took over on March 31, 2023. FY2020, FY2021 and FY2022 were not completed and submitted. By the time that these three were caught up, completed and submitted, that pushed FY2023 Audit to be late. The audit for FY2023 should be completed by the end of April 2025 and then we will be on task to start FY2024 in May and completed by the deadline of September 30, 2025. Then, RHA will stay on task and get these completed within its deadline timeline.
NIYC has developed new policies and procedures that clearly state that two signers are required for each check and who is authorized to sign checks. Furthermore, NIYC has had a transition of leadership. During the transition, it was communicated the requirement of having two signatures for each chec...
NIYC has developed new policies and procedures that clearly state that two signers are required for each check and who is authorized to sign checks. Furthermore, NIYC has had a transition of leadership. During the transition, it was communicated the requirement of having two signatures for each check as well as any additional corrective action plans.
2023-004 Internal Control Over Eligibility and Compliance Over Eligibility - U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee...
2023-004 Internal Control Over Eligibility and Compliance Over Eligibility - U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award. For services to be provided under the Housing Opportunities for Persons with AIDS, individuals requesting services must meet criteria under the grant which includes providing identification and validating proof of HIV/AIDS diagnosis, income, rent or mortgage payment, and need for assistance. A full validation of these criteria is required to be performed for any individual receiving assistance. Condition: Of 21 files selected for individuals who received assistance under the grant, one selection included two copies of the same support for the client’s need for assistance that contained differing amounts for that client’s earnings during the same period which may be indictive of fraud in the application process. No documentation was included in the client file addressing the inconsistency and related risk of fraud for the earnings and the client was determined to be eligible for assistance when the existence of duplicative information that was not addressed or resolved would make it not possible to determine eligibility for this client. Cause: AFAN had designed controls such that each client file would be reviewed by the lead case manager for proper support of eligibility requirements. However, this internal control system did not detect the duplicative eligibility support that may have been indicative of fraud in the application process, nor did the internal control system identify the individual as being ineligible before providing assistance to the individual. Context: Management failed to consistently and effectively perform an internal control to address the risk of ineligible individuals receiving financial assistance. Effect: Failure to properly perform controls over the review of the client files could result in providing assistance to individuals who are not eligible. The allowance of individuals to receive or continue receiving services without ensuring they meet the eligibility criteria is a violation of the terms of the federal grant agreement. Repeat Finding: No Recommendation: We recommend management design and implement a system of internal controls whereby a review of client files to ensure eligibility is properly supported is performed before any grant funds are disbursed and that management ensures proper documentation of this review is maintained to support the performance of the control. Views of Responsible Officials and Planned Corrective Actions: Management intends to put in place additional training for case managers to identify eligibility of clients and ensure proper backup is submitted. Supervisors will ensure all backup is included in the case file before being submitted.
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