Finding Text
2022-01 Duplicate Payments
Federal Agency: U.S. Department of the Treasury
Federal Program Name: Emergency Rental Assistance (ERA) 1 & 2
Assistance Listing Number: 21.023
Federal Award Identification Number: ERA0113 & ERA0104 (pass through Marion County)
Award Period: 06/30/2022
Type of Finding: Significant Deficiency in Internal Control over Compliance and Internal Control
Over Financial Reporting
Criteria: The U.S. Department of the Treasury’s Emergency Rental Assistance (ERA) program
requires compliance with limits on the maximum amount paid to program participants and
limits on the period of reimbursements.
Condition: During the audit we found that the implementation of internal controls meant to
prevent duplicate payments was inadequate.
Effect: This resulted in duplication of benefits to 30 identified participants. This failure in internal
control could have resulted in exceeding allowable limits for amounts paid to participants,
though in sampled participants we determined that all duplicated amounts were within program
maximums.
Cause: The identified issues stem from deficiencies in internal controls over payment
verification. For ERA 1 United Way processed all payments to participants and failed to verify
whether payments had already been made before processing additional payments. This was
likely due to a failure to upload proof of payment in a timely manner and a lack of any digital
system to monitor or detect duplicate payments. For ERA 2 United Way paid for applications that
were filed in the ERA 2 database which Capital Access was responsible for paying causing
duplicate payments.
Recommendation: For grant related expenditures not processed through the standard accounts
payable process we recommend that United Way keep a separate listing of payments made and
search that list before authorizing new payments to eliminate duplication. Additionally, United
Way should verify applications are filed in the ERA 1 database with Capital Access before issuing
payments.
Context: We conducted a random sample of 60 participants and did not detect any duplicates.
However, we were made aware of duplicates as identified in the reconciliations provided by
United Way, which were completed in collaboration with the County. We then reviewed these
identified duplicates to verify that they were indeed duplicates and sampled them to ensure
payments were not in excess of allowable limits.