Finding Text
REPORTING - SIGNIFICANT DEFICIENCY
Federal Program
Community Development Block Grant/Entitlement Grant ALN 14.218; passed through the County of Berks
Emergency Rental Assistance ALN 21.023; passed through the County of Berks
Criteria
Section 3 of the Housing and Urban Development Act of 1968 requires reporting of certain data on an annual basis related to the Community Development Block Grant to ensure that employment and other economic opportunities generated by certain HUD financial assistance programs shall, to the greatest extent feasible, and consistent with existing federal, state, and local laws and regulations, be directed to low- and very-low income persons, particularly those who are recipients of government assistance for housing, and to business concerns which provide economic opportunities to low- and very-low income persons.
The Emergency Rental Assistance grant agreements each contain reporting requirements for both monthly and quarterly reports. Treasury has issued reporting guidance to all grantees.
Condition/Cause
The Authority did not maintain documentation of internal controls over reporting for the programs.
For required Community Development Block Grant Reporting under Section 3 of the Housing and Urban Development Act of 1968, total Labor Hours reported for 2022 did not agree to support maintained.
Additionally, for the Emergency Rental Assistance program, while reporting spreadsheets were provided, supporting documentation for the amounts reported were not maintained.
Effect
The Authority did not have documentation to support an internal control over reporting. Documentation does not support Section 3 labor hours reported for the year. Additionally, as certain files were over-written, the Authority could not produce documentation to support emergency rental assistance information reported.
Questioned Costs
None.
Context
During our testing of Community Development Block Grant reporting, we requested the Section 3 report filed for 2022. Total labor hours reported were 1,202 but should have been reported as 770 hours based on certified payroll documentation maintained.
During our testing of Emergency Rental Assistance Program reporting, we sampled 15 reports, including both monthly and quarterly reporting. While the Authority could provide certain spreadsheets, a detail of supporting documentation could not be provided for 9 out of the 15 reports selected for testing.
Repeat Finding
Yes. 2021-007.
Recommendation
We recommend that all grant reports are reviewed by a person independent of the preparer who has knowledge of the grant requirements. This review should include comparing the amounts reported to detailed support for accuracy. We also recommend the Authority review their recordkeeping procedures for documentation related to grant reporting. There should be a process in place to ensure all required documentation is maintained and filed in an orderly system that allows the Authority to locate and provide documentation when required.
Management Response
See corrective action plan included in this report package.