Finding 10815 (2023-001)

-
Requirement
ABE
Questioned Costs
$1
Year
2023
Accepted
2024-01-30

AI Summary

  • Core Issue: $40,000 in payments were made for ineligible participants under the ERAP, with an additional $226,190 identified under the RAFT program.
  • Impacted Requirements: Payments must only go to participants at risk of homelessness with incomes at or below 80% of the area median income.
  • Recommended Follow-Up: Management should enhance policies and procedures for payment reviews to ensure compliance with eligibility criteria.

Finding Text

2023-001 Payments on behalf of Ineligible Participants Federal Agency: U.S. Department of the Treasury Federal Program: 20.023 Emergency Rental Assistance Program (ERAP) Condition Management identified four payments under the ERAP totaling $40,000 for the year ended June 30, 2023, that were made on behalf of ineligible participants. Additionally, management identified additional payments on behalf of ineligible participants under the non-federal Rental Assistance for Families in Transition (RAFT) program during the period July 1, 2021 through December 31, 2023. Management identified 27 ineligible payments totaling $226,190 made under the two programs for the period July 1, 2021 through December 31, 2023. Context No exceptions were found in a non-statistically valid sample of forty disbursements totaling $82,443 under the ERAP. The population for the ERAP disbursements was 3,612 totaling $6,645,726. The ineligible payments were detected through non-sampling procedures. Criteria Financial assistance to households including payments of rent, rental arrears, utilities and home energy costs, utility and home energy costs arrears and other expenses relating to housing must be paid to participants whom are at risk of homelessness and have household income levels at or below 80% of the area median income. Cause Manual overrides in EOHLC’s online payment system were used to process payments that did not pass the initial verification process. Effect Certain payments were not made to or on behalf of eligible participants in accordance with program regulations. Questioned Costs $40,000 Repeat Finding No Recommendation We recommend management continue to work with EOHLC to develop additional policies and procedures over the review, approval and payments process to ensure funding is only provided to or on behalf of eligible participants in accordance with program regulations. Management Response Management agrees with the finding. See management’s attached corrective action plan.

Corrective Action Plan

2023-001 Payments on behalf of Ineligible Participants Responsible Official Janette Vigo, Chief Program Officer Plan Detail Although we currently have strong processes in place to flag and identify most ineligible payments before they are made, Way Finders will continue our work internally to determine and implement additional measures as recommended by the Executive Office of Housing and Livable Communities (EOHLC). We will hire an independent firm to perform a programmatic audit including a review of any applications processed using manual system overrides. We will request that EOHLC tighten access for all users and limit override abilities solely to the compliance team. We will also implement a monthly review of all overrides in the system to proactively evaluate potential risks within the system to prevent similar ineligible payments. Additionally, management has established a Fraud Risk Oversight Committee (FROC) whose members are the CEO, CFO, Chief Legal Officer, Chief Program Officer, and SVP of Housing Education Services. The FROC will oversee the implementation of the corrective action plan and report on a quarterly basis to the Board of Directors, Finance and Audit Committee. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in fiscal year 2024.

Categories

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $42.11M
21.023 Emergency Rental Assistance Program $6.62M
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $4.78M
59.012 7(a) Loan Guarantees $2.38M
11.307 Economic Adjustment Assistance $951,904
14.880 Family Unification Program (fup) $396,868
21.U01 Neighborworks Grant Funds $393,250
14.871 Section 8 Housing Choice Vouchers $332,110
14.896 Family Self-Sufficiency Program $233,800
59.046 Microloan Program $225,000
14.181 Supportive Housing for Persons with Disabilities $194,081
14.218 Community Development Block Grants/entitlement Grants $170,000
21.024 Community Development Financial Institutions Rapid Response Program (cdfi Rrp) $169,584
14.408 Fair Housing Initiatives Program $50,332
14.169 Housing Counseling Assistance Program $48,328
14.267 Continuum of Care Program $33,969
14.252 Section 4 Capacity Building for Community Development and Affordable Housing $25,600
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $15,100
10.596 Pilot Projects to Reduce Dependency and Increase Work Requirements and Work Effort Under Snap $4,856