Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investm...
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investment Partnerships and Housing Trust Funds Programs: Fountain Springs - Loan Mayor and City of Baltimore: Baltimore Housing - Park Heights Women and Children - Loan Type of Finding: - Material Weakness in Internal Control over Compliance - Other Matters Condition: As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless). Of 40 resident client files reviewed, management could not provide proof of income or residency status for 16 clients, or policies and procedures manuals for 22 clients. Recommendation: We recommend that management adopt and implement formal policies and procedures to ensure compliance with HOME eligibility requirements. Such policies and procedures should include clear communication of compliance requirements between staff and locations, standardized documentation and processes for determining and verifying income eligibility during intake, and procedures for the redetermination of income eligibility for residential clients residing at a location for more than one year. Repeat Finding: 2024-001 Explanation of Disagreement with Audit Finding Management acknowledges the finding and continues to strengthen internal controls related to HOME program compliance, including eligibility documentation and file retention practices across all residential program locations. Management agrees that consistent documentation of eligibility, including proof of income and residency status (as applicable under HOME requirements), is critical. We are currently reviewing and enhancing intake procedures, documentation standards, and internal monitoring processes to ensure all required eligibility documentation is properly obtained, maintained, and uniformly applied across all locations. Action taken in response to finding: In response to the recommendation, management will develop and implement formalized policies and procedures to strengthen compliance with HOME requirements. These will include standardized guidance for eligibility determination at intake, clear documentation requirements across all sites, and procedures for ongoing eligibility review for clients residing in programs beyond one year. Name of the contact person responsible for corrective action: Dr. Deja Gilbert, PhD, MDA, FACHE, LPC, LMHC, President and CEO dgilbert@gaudenzia.org Planned completion date for corrective action plan: June 30, 2026