Finding 1145886 (2024-004)

2024-004 Type of Finding: Material Weakness in Internal Control over Compliance Federal Agency: Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: WA005VOW089-WA005VOW094 – 2024 Pass-Through Agency: Pierce County Pass-Through Number: SC-110242 & SC-111165 Award Period: July 1, 2023 – June 30, 2024; July 1, 2024 – June 30, 2025 Criteria or Specific Requirement: 2 CFR 200.302(a) on Financial management states that “All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award". Condition: During Activities Allowed or Unallowed; Allowable Costs / Cost Principles testing, 3 of the 40 samples selected did not include sufficient documentation to support the amount charged to the major program. After fieldwork was completed, the client produced the necessary documentation for the 3 samples. During Eligibility testing, 2 of the 8 samples selected did not include sufficient documentation to support the amount charged to the major program. After fieldwork was completed, the client produced the necessary documentation for the 2 samples. During Special Tests and Provisions testing, 2 of the 16 samples selected did not retain documentary evidence of compliance with the Rent Reasonableness and Housing Quality Standards requirements. After fieldwork was completed, the client produced the necessary documentation for the 2 samples. Questioned Costs: None Context: Activities Allowed or Unallowed; Allowable Costs / Cost Principles: A sample of 40 disbursements were taken from a population of over 250 individual charges to the major program. Of the 40 sampled, 3 were insufficiently supported to agree to the amount charged to the major program. After fieldwork was completed, the client produced the necessary documentation for the 3 samples. Eligibility: A sample of 8 was made from a population of 63 major program participants. Of the 8 sampled, 2 had benefit costs that were insufficiently supported to agree to the amount charged to the major program. After fieldwork was completed, the client produced the necessary documentation for the 2 samples. Special Tests and Provisions: A sample of 8 was made from a population of 63 major program participants, each with two Special Tests and Provisions requirements (Rent Reasonableness and Housing Quality Standards) for a total of 16 samples. Of the 8 participants sampled, 1 file did not include a Rent Reasonableness Checklist and Certification form nor a Housing Quality Standards Inspection form. After fieldwork was completed, the client produced the necessary documentation for the 2 samples. Cause: Support was not found during fieldwork, as source documentation related to payments made for program participants are inconsistently retained in the participant's files. Documentation should be ready for audit at the time of fieldwork. Effect: Without adequate documentation in place to ensure costs are evidenced and reconcile to the expenditures documented in the underlying accounting information that is used to prepare the SEFA, Associated Ministries of Tacoma - Pierce County could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement that Associated Ministries of Tacoma - Pierce County is entitled to under the terms of the grant. Repeat Finding: No. Recommendation: CLA recommends that Associated Ministries of Tacoma - Pierce County implement a policy to retain all invoices, receipts, bills, and other similar source documents within each client file behind each Check Request form. In addition, program staff should retain a clear paper trail that documents the difference between monthly rent as specified on the lease agreements to the amount disbursed on behalf of the participant. This will enhance clarity of costs attributable to the major program. View of Responsible Officials: There is no disagreement with the audit finding.