Finding Text
Finding 2024-003: Activities Allowed and Allowable Costs - see prior year finding 2023-003
Criteria
ESG funds may be used for five program components: street outreach, emergency shelter, homelessness prevention, rapid re-housing assistance, and HMIS; as well as administrative activities. The five program components and the eligible activities that may be funded under each are set forth in 24 CFR 576.101 through 576.107.
Condition/Context
Based on a report by a forensic investigator and Catholic Charities it was determined supportive service expenditures were processed and paid for ineligible participants. However, based on the same report it was determined there could be additional costs that were processed and paid for ineligible participants. In addition, due to Wipfli LLP's audit procedures it was determined that the breakdown in internal controls over the review of participant eligibility and review of payments made for participants was significant and we cannot obtain sufficient audit evidence to support these payments.
Questioned Costs
$21,478
How the Questioned Costs were Computed
Total Amount Charged to the Program from forensic report that were documented as Improper, Inconclusive or Insufficient Information.
Cause
Due to lack of supervisory oversight and lack of review of required documentation to support invoices to be paid to participants, several employees falsified participant documents whereby ineligible individuals with personal relationships to these employees receive assistance payments.
Effect
Management became aware of the improprieties and hired an independent forensic investigator. The forensic investigator identified improper disbursements to ineligible participants along with other disbursements that required further research, inconclusive, insufficient, unverified, and LLC discrepancy disbursements. Management also notified the State of New Jersey Department of Community Affairs Office of Auditing.
Recommendation
Management should strengthen controls over documentation required for participants to receive assistance payments along with controls over review of documentation in participant files and processing of these payments.
View of Responsible Officials
Management agrees with the recommendation and have begun implementing additional procedures to ensure applicant files are complete and case files and support are being reviewed by supervisory personnel.