Finding Text
Finding 2024-001 – Significant Deficiency: Reporting – Compliance and Control Finding
ALN 14.241 – Housing Opportunities For Persons With AIDS (H.O.P.W.A.)
Federal Agency: U.S. Department of Housing and Urban Development
Pass-Through Entity: None
Criteria Or Specific Requirement: Pursuant to 24 Code of Federal Regulations 574.520, Interfaith Residence d/b/a Doorways is required to submit an annual report. Per the Uniform Guidance, this report is HUD-4155 H.O.P.W.A. Consolidated Annual Performance Report(APR)/Consolidated Annual Performance and Evaluation Report (CAPER). The report is to be submitted no later than 90 days after the close of the program or operating year.
Condition: Interfaith Residence d/b/a Doorways did not submit the CAPER within 90 days after the close of the operating year.
Cause: The delay in the submission was due to the staffing/capacity issues caused by the unanticipated absorption of work from the sudden closing of the Outstate Missouri program’s long-time subrecipient. The additional responsibilities combined with internal staff turnover resulted in an unusual amount of time to ensure key data for the CAPER was accurate and comprehensive. Controls over compliance were not put in place by management as it relates to this compliance requirement.
Effect: Interfaith Residence d/b/a Doorways did not meet the compliance reporting requirements set forth by the U.S. Department of Housing and Urban Development.
Questioned Costs: Not applicable.
Context: Interfaith Residence d/b/a Doorways did not ensure guidelines from the U.S. Department of Housing and Urban Development were followed to ensure timely reporting.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management implement controls and processes to ensure that all due dates for reporting are appropriately monitored and reports are submitted timely to meet the reporting due dates.
Views Of Responsible Officials: Fiscal 2024 was a highly unusual year for DOORWAYS’ H.O.P.W.A. program due to the sudden cessation of housing operations by the Outstate Missouri program’s long-time subrecipient, Spectrum Health Care, in May 2023, resulting in an early termination of the subrecipient service contract. This stoppage of service came without advance warning and necessitated that DOORWAYS, through an agreement with HUD, take over direct program operations to ensure clients living in rural Missouri did not experience a disruption in housing provision. The sudden influx of work required from absorbing direct program performance, coupled with internal staff turnover in the position that oversees this program, led to reduced department capacity and oversight of the Consolidated Annual Performance and Evaluation Report (CAPER) filing. Management recognized the need for additional staff capacity to administer all required duties and hired an Outstate Program and Grants Manager on February 1, 2025 to focus on these tasks. The position is overseen by the Director of Government Grants and Compliance, who is knowledgeable about the service and reporting requirements of this program. Additionally, starting in February 2025, the team implemented bi-monthly meetings to update the Chief Financial Officers on progress and timely filing of all grants related reporting to ensure all deadlines are met.