Finding Text
Program Information:
U.S. Department of Housing and Urban Development
Indian Housing Block Grant
Assistance Listing #14.867
Award Numbers: 55-IH-53-18320
Award Period: 10/18/2011 – 09/30/2034
Criteria: Per the 2024 OMB Compliance Supplement, each recipient shall develop written policies governing the eligibility, admission, and occupancy of families for housing assisted with grant funds (25 USC 4133(d)).
Per YNHA policies, all program applicants must meet the following eligibility requirements:
• Qualify as an Indian Family or qualify for an exception - YNHA may decide to provide housing assistance for non-Indian family if they deem the presence of the family on the reservation is essential to the well-being of Indian families and the need for housing of essential families cannot reasonably be met without such assistance (ex. teachers, healthcare providers). Executive Director will make a determination for essential families. YNHA may also provide housing for law enforcement officers of the Nation or another unit of government and YNHA determines the presence of the officer may deter crime.
• Have an annual income that meets income eligibility standards (considered low-income based on HUD thresholds) or qualify as an exception. Families that are not low-income can receive assistance in a few cases: they were low income at the time of initial occupancy, they received a Mutual Help unit through transfer of the unit from a family member, or the family is an essential family/law enforcement (see above).
• Be 18 years or older or 16 with status as an emancipated minor.
• Provide a complete application including proof of tribal enrollment, social security cards, and proof of income.
• Signed Consent for Release of Information to YNHA/HUD Form 9886.
• Must submit to drug and alcohol screening tests prior to signing the rental agreement, lease, or homeownership agreement.
• Annual inspections.
2 CFR § 200.303 - Internal controls states, the non-federal entity must:
(a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: During testing of 30 tenant files under the IHBG program:
• 2 of 30 files did not include a signed rental agreement documenting initial eligibility approval.
• 30 of 30 files lacked evidence of approval of recertifications or required inspections.
[ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness
Cause: YNHA’s internal control procedures over eligibility and recertification were not consistently followed. Management did not ensure that signed agreements and approvals of recertifications/inspections were documented in the tenant files.
Effect: Failure to document eligibility determinations and approvals creates a risk that ineligible tenants may receive housing benefits, that federal program requirements may not be met, and that YNHA may be subject to HUD compliance findings.
Questioned Cost: N/A – The documentation deficiencies identified did not result in known unallowable costs or payments to ineligible participants; therefore, no questioned costs are reported.
Prior Year Finding: No.
Recommendation: We recommend that YNHA implement written procedures and staff training to ensure all required eligibility and occupancy documentation is obtained and retained.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.