FINDING # 2022-008No finding in prior yearU.S. Treasury?s COVID-19 Emergency Rental Assistance Program (ERA) was established in 2021 to support housing stability throughout the pandemic by providing assistance payments for renters facing eviction. The Department of Community Affairs (DCA) is a dire...
FINDING # 2022-008No finding in prior yearU.S. Treasury?s COVID-19 Emergency Rental Assistance Program (ERA) was established in 2021 to support housing stability throughout the pandemic by providing assistance payments for renters facing eviction. The Department of Community Affairs (DCA) is a direct recipient of ERA funding for use in preventing evictions for over 70,000 families throughout the State of New Jersey.Since the rollout of the new ERA program back in 2021, the reporting requirements and guidance provided by U.S. Treasury to ERA recipients evolved with numerous changes and updates posted that also required DCA to change and update systems over time. As the programs continued to evolve so did DCA?s reporting process. U.S. Treasury initially required monthly reporting starting in April 2021, through which ERA recipients provided U.S. Treasury with very high-level counts of the numbers of households receiving assistance and the amounts of ERA funds distributed. The monthly reporting requirement was then discontinued after the June 30, 2022 submission and thereafter, U.S. Treasury shifted the ERA Reporting guidance to be focused primarily on the quarterly reporting requirements and also amended those reporting requirements going forward.When preparing monthly and quarterly reports, DCA?s data source used has always been the most reliable one at the time the report was due in order to ensure accuracy of information reported to U.S. Treasury. As previously stated, DCA?s systems evolved as needed in order to keep up with the constant changes in reporting requirements for the ERA program.? At the inception of the program, reporting was done from the primary Podio system that obligated and requested payments.? DCA then worked to build the necessary reports from the MRI system that generated ERA payments in order to trace payments back to checks issued ? representing distributions incurred.? Most recently DCA has been working to reconcile MRI with the State?s NJCFS accounting system to further validate the MRI data. Over time variances have been identified that affect reporting such as void and uncashed check actions.DCA recognizes the need to ensure supporting documentation used to prepare quarterly and other required reports for Treasury is captured and retained for audit purposes. DCA continues to build?a three-way reconciliation between the three primary systems to document explainable variances among the systems, such as timing differences, voids, returned items, etc. DCA has implemented a corrective action plan to enhance the availability of supporting documentation for ERA Treasury reporting.Corrective Action Plan:A. ERA Monthly reports are no longer required by Treasury. No further action is needed.B. ERA Quarterly Reports and Final ReportsI. On a monthly basis, Podio, MRI and Treasury data will be reconciled with variances identified (typically voids and uncashed checks).II. The Quarterly report files will be generated for retention, and an explanatory memo will accompany it. The memo will include the following:Quarterly Reporting Explanatory Memo:Contents:1. Source of Data used to generate the reports.a. If the source changed from the prior quarter, then an explanation will be provided.2. Date the source data was pulled.a. Listed by source if multiple sources are being used.3. Changes in approach.a. Any change in the approach used to prepare the reports will be documented, including internal changes and those issued by US Treasury.b. If Treasury issues guidance that changes reporting requirements, then such guidance will be included as an attachment to the memo.4. Recommendation by the Program Director, or his/her delegate, to proceed with submitting the Report.5. If an extension was requested, the memo will be updated to include the reason and justification for the extension.6. Submission Confirmation. Documented confirmation by DCA, or its delegate, that the quarterly report was submitted.7. At times, Treasury makes changes to the portal that are not communicated ahead of time. Any change or issues with the submission will be documented.8. DCA will download a copy of the final submission file from DCA?s portal.9. The memo, submission, .csv files, and final PDF file from treasury?s portal will be saved to a secure folder.?COMPLETION DATE/CONTACT PERSON June 30, 2023Elena Gaines(609) 913-4468Elena.Gaines@dca.nj.gov