Finding Text
Finding 2024-003: Eligibility – Lack of Internal Controls Federal Program: Rural Rental Housing Loans – Assistance Lising #10.415 Federal Agency: U.S. Department of Agriculture - Rural Development Award Period: 2024 Finding resolution status Unresolved Information on universe and population size The universe consisted of tenant files of all tenants living in projects financed with rural rental housing loans (143) during the fiscal year. Sample size information 15 tenant files were reviewed. Identification as a repeat finding This is not a repeat finding. Criteria 2 CFR §200.303(c) requires non-Federal entities to establish and maintain effective internal controls over Federal awards that provide reasonable assurance of compliance with applicable laws, regulations, and program requirements. As a fundamental internal control principle, review of key financial and program compliance documents, including tenant certifications, should be performed by an individual independent from the preparer to prevent and detect errors or misstatements. Statement of condition During our testing of compliance for eligibility, we noted that the same employee was responsible for both preparing and reviewing the tenant files. Cause The organization has limited staffing resources, resulting in the assignment of incompatible duties to a single employee without sufficient compensating controls. Effect When the preparer is also the reviewer, the risk of undetected errors or omissions increases. This could result in inaccurate tenant certifications, noncompliance with RD program requirements, and potential misreporting of tenant eligibility or rental assistance amounts. Auditor non-compliance code S – Internal Control Deficiency Questioned costs None Views of responsible officials Management concurs with the finding and will take steps to resolve the material weakness. Context This issue was observed in the preparation and review process for RD Form 3560-8 and/or HUD Form 50058, where staffing limitations resulted in the same individuals both preparing and reviewing tenant certifications. Recommendation We recommend that the Authority establish procedures to ensure all RD Form 3560-8 and HUD Form 50058 submissions are subject to an independent review prior to submission.