FAC Explorer

Finding 1074708 (2023-001)

Material Weakness
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2024-09-25
Audit: 321037
Organization: City of Seattle (WA)
Auditor: Office of the Washington State Auditor

AI Summary

  • Core Issue: The City lacked adequate internal controls for monitoring subrecipients, leading to noncompliance with federal requirements for the HOPWA program.
  • Impacted Requirements: Federal regulations mandate risk assessments and monitoring of subrecipients to ensure compliance with program eligibility and housing quality standards.
  • Recommended Follow-Up: The City should implement risk assessments, enhance monitoring processes, and provide training for staff to ensure compliance with federal program requirements.

Finding Text

2023-001 The City’s internal controls were inadequate for ensuring compliance with federal subrecipient monitoring requirements. Assistance Listing Number and Title: 14.241, Housing Opportunities for Persons With AIDS 14.241, COVID-19 - Housing Opportunities for Persons With AIDS Federal Grantor Name: U.S. Department of Housing and Urban Development Federal Award/Contract Number: WAH20-0114, COVID-19 WAH20-F001, WAH21-F001, WAH22-F001 Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The purpose of the Housing Opportunities for Persons With AIDS (HOPWA) program is to provide states and localities with resources and incentives to devise long-term strategies for the housing needs of people living with HIV, including those with AIDS or related diseases, and their families. During fiscal year 2023, the City spent $3,589,690 in program funds for emergency housing, shared housing arrangements, apartments, single room occupancy (SRO) dwellings, community residences, and essential care services and supplies such as food, medications, medical care, personal protective equipment and information. The City passed down $3,545,285 to subrecipient organizations to execute these arrangements. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal regulations require the City to clearly identify the subaward contract as a federal award and include all applicable program requirements when passing on federal funding to subrecipients. Further, the City must monitor its subrecipients to ensure they comply with the federal award’s terms and conditions. To determine the appropriate level of monitoring, the City must evaluate each subrecipient’s risk of noncompliance with federal requirements. For this award, monitoring would include verifying subrecipients provided assistance to participants who met program eligibility requirements and performed inspections for Housing Quality Standards (HQS) outlined in 24 CFR sections 574.310(b)(1)-(2). The amount of verification would depend on each subrecipient’s risk of noncompliance. Description of Condition The City provided funds to seven local organizations to administer housing assistance programs for people living with HIV, including those with AIDS or related diseases. The City did not have internal controls to ensure compliance with subrecipient monitoring requirements. Our audit found the City did not perform risk assessments for subawards and did not sufficiently monitor subrecipients as federal regulations require. We consider these deficiencies in internal control to be a material weakness that led to material noncompliance. Cause of Condition Due to staff turnover, new staff were unaware of all monitoring requirements. Additionally, for two of the four subrecipients audited, City staff said they believed risk assessments and monitoring were not required for those contracts under the HOPWA Housing as an Intervention to Fight AIDS (HIFA) because it was a new pilot program. The City could not provide documented support that risk assessment and monitoring requirements were waived for this program. Effect of Condition The City did not perform risk assessments nor adequately monitor three of four subrecipients we reviewed during the audit. By not conducting risk assessments, the City risks inadequately monitoring its subrecipients to ensure it complies with program requirements and uses federal funds appropriately. Since the City did not monitor its subrecipients, there was no way for it to confirm the subrecipients provided funds to eligible recipients and that housing units met HQS inspection requirements. Recommendation We recommend the City perform sufficient risk assessments over its subrecipients and monitor them accordingly to verify they are complying with the award’s terms and conditions and only providing funds to eligible participants. Additionally, we recommend the City provide adequate training to staff responsible for administering federal programs and dedicate the necessary time and resources to staying updated on program guidance and ensuring compliance with all program requirements. City’s Response HSD acknowledges the identified issues, which were primarily due to a long-term vacancy of key staff responsible for conducting these duties. HSD notes that these are multi-year grants, with previously assessed contracted providers who have experience administering these funding sources for multiple years on behalf of the city. Therefore, HSD prioritized ensuring that essential services and agreements continued uninterrupted to prevent homelessness among vulnerable populations. The vacancy was filled as of October 2023. Risk assessments and monitoring plans are now in place and are expected to be completed before December 2024. Staff is trained on the most current HOPWA procedures and CAPER reporting requirements. HSD remains committed to dedicating the necessary resources to ensure ongoing compliance with all relevant program requirements, while also reinforcing its capacity to deliver essential services to those in need. Auditor’s Remarks We appreciate the City’s commitment to resolving this finding and thank the City for its cooperation and assistance during the audit. We will review the corrective action taken during the next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, section 332, Requirements for passthrough entities, establishes subrecipient monitoring and management requirements for pass-through entities.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 498263 2023-001
    Material Weakness
  • 498264 2023-001
    Material Weakness
  • 498265 2023-001
    Material Weakness
  • 498266 2023-001
    Material Weakness
  • 498267 2023-002
    Material Weakness
  • 498268 2023-002
    Material Weakness
  • 498269 2023-002
    Material Weakness
  • 498270 2023-002
    Material Weakness
  • 498271 2023-003
    Significant Deficiency
  • 498272 2023-003
    Significant Deficiency
  • 498273 2023-003
    Significant Deficiency
  • 498274 2023-003
    Significant Deficiency
  • 498275 2023-003
    Significant Deficiency
  • 498276 2023-004
    - Repeat
  • 498277 2023-004
    - Repeat
  • 498278 2023-004
    - Repeat
  • 498279 2023-004
    - Repeat
  • 498280 2023-004
    - Repeat
  • 498281 2023-004
    - Repeat
  • 498282 2023-004
    - Repeat
  • 498283 2023-004
    - Repeat
  • 498284 2023-004
    - Repeat
  • 498285 2023-005
    Material Weakness Repeat
  • 498286 2023-005
    Material Weakness Repeat
  • 498287 2023-005
    Material Weakness Repeat
  • 498288 2023-005
    Material Weakness Repeat
  • 498289 2023-005
    Material Weakness Repeat
  • 498290 2023-005
    Material Weakness Repeat
  • 498291 2023-005
    Material Weakness Repeat
  • 498292 2023-005
    Material Weakness Repeat
  • 498293 2023-005
    Material Weakness Repeat
  • 498294 2023-006
    Significant Deficiency
  • 1074705 2023-001
    Material Weakness
  • 1074706 2023-001
    Material Weakness
  • 1074707 2023-001
    Material Weakness
  • 1074709 2023-002
    Material Weakness
  • 1074710 2023-002
    Material Weakness
  • 1074711 2023-002
    Material Weakness
  • 1074712 2023-002
    Material Weakness
  • 1074713 2023-003
    Significant Deficiency
  • 1074714 2023-003
    Significant Deficiency
  • 1074715 2023-003
    Significant Deficiency
  • 1074716 2023-003
    Significant Deficiency
  • 1074717 2023-003
    Significant Deficiency
  • 1074718 2023-004
    - Repeat
  • 1074719 2023-004
    - Repeat
  • 1074720 2023-004
    - Repeat
  • 1074721 2023-004
    - Repeat
  • 1074722 2023-004
    - Repeat
  • 1074723 2023-004
    - Repeat
  • 1074724 2023-004
    - Repeat
  • 1074725 2023-004
    - Repeat
  • 1074726 2023-004
    - Repeat
  • 1074727 2023-005
    Material Weakness Repeat
  • 1074728 2023-005
    Material Weakness Repeat
  • 1074729 2023-005
    Material Weakness Repeat
  • 1074730 2023-005
    Material Weakness Repeat
  • 1074731 2023-005
    Material Weakness Repeat
  • 1074732 2023-005
    Material Weakness Repeat
  • 1074733 2023-005
    Material Weakness Repeat
  • 1074734 2023-005
    Material Weakness Repeat
  • 1074735 2023-005
    Material Weakness Repeat
  • 1074736 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $36.45M
66.958 Water Infrastructure Finance and Innovation (wifia) (e) $34.24M
93.778 Medical Assistance Program $10.54M
66.458 Capitalization Grants for Clean Water State Revolving Funds $9.00M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $8.69M
21.023 Emergency Rental Assistance Program $5.19M
21.016 Equitable Sharing $3.94M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $2.48M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $2.42M
97.091 Homeland Security Biowatch Program $1.66M
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $1.39M
14.239 Home Investment Partnerships Program $1.31M
16.922 Equitable Sharing Program $1.14M
93.052 National Family Caregiver Support, Title Iii, Part E $738,424
97.108 Homeland Security, Research, Testing, Evaluation, and Demonstration of Technologies $721,140
97.047 Bric: Building Resilient Infrastructure and Communities $716,410
10.558 Child and Adult Care Food Program $666,904
14.241 Housing Opportunities for Persons with Aids $637,090
14.881 Moving to Work Demonstration Program $630,550
16.543 Missing Children's Assistance $592,392
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $510,428
93.564 Child Support Enforcement Research $485,553
93.053 Nutrition Services Incentive Program $480,821
97.042 Emergency Management Performance Grants $451,101
20.500 Federal Transit_capital Investment Grants $447,835
16.738 Edward Byrne Memorial Justice Assistance Grant Program $415,453
45.024 Promotion of the Arts_grants to Organizations and Individuals $410,500
97.044 Assistance to Firefighters Grant $409,141
20.525 State of Good Repair Grants Program $367,832
10.559 Summer Food Service Program for Children $247,016
14.218 Community Development Block Grants/entitlement Grants $226,417
16.320 Services for Trafficking Victims $208,391
93.569 Community Services Block Grant $180,466
84.047 Trio_upward Bound $166,434
93.568 Low-Income Home Energy Assistance $149,721
15.916 Outdoor Recreation_acquisition, Development and Planning $132,765
16.835 Body Worn Camera Policy and Implementation $128,368
16.582 Crime Victim Assistance/discretionary Grants $127,953
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $126,276
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $123,832
93.969 Pphf Geriatric Education Centers $118,077
97.067 Homeland Security Grant Program $85,998
20.941 Strengthening Mobility and Revolutionizing Transportation (smart) Grants Program $80,794
16.710 Public Safety Partnership and Community Policing Grants $78,414
16.575 Crime Victim Assistance $70,143
20.616 National Priority Safety Programs $50,203
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $45,852
93.493 Congressional Directives $40,521
14.231 Emergency Solutions Grant Program $38,052
16.838 Comprehensive Opioid Abuse Site-Based Program $29,516
20.600 State and Community Highway Safety $27,030
81.042 Weatherization Assistance for Low-Income Persons $26,498
14.251 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants $24,000
11.438 Pacific Coast Salmon Recovery_pacific Salmon Treaty Program $22,518
20.205 Highway Planning and Construction $21,301
97.039 Hazard Mitigation Grant $21,062
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $16,994
10.576 Senior Farmers Market Nutrition Program $7,025
16.034 Coronavirus Emergency Supplemental Funding Program $5,232
45.310 Grants to States $4,451
20.507 Federal Transit_formula Grants $3,634
97.056 Port Security Grant Program $1,777
32.011 Affordability Connectivity Outreach Grant Program $1,707