Finding 1164523 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-11
Audit: 374094
Organization: Amherst H. Wilder Foundation (MN)

AI Summary

  • Core Issue: There is a significant weakness in internal controls regarding rent payments, leading to potential noncompliance with federal requirements.
  • Impacted Requirements: Rent must be reasonable compared to local rates and cannot exceed what the same owner charges for similar unassisted spaces.
  • Recommended Follow-Up: Establish a formal policy for documenting rent reasonableness procedures and ensure proper reviews are conducted before payments are made.

Finding Text

Federal Agency: Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Numbers: MN0048L5K012316, MN0269L5K012211, MN0269L5K012312 Award Periods: 7/1/2024 – 6/30/2025, 1/1/2024 – 12/31/2024, 1/1/2025 – 12/31/2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Qualified Opinion) Criteria or specific requirement: Where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space (24 CFR 578.49(b)(1) and 24 CFR 578.51(g)) Condition: During our audit testing, we noted rent reasonableness documentation was not performed or performed after the rent expenses were paid. Context: During our testing 7 out of the 8 selections either did not have a rent calculation form filled out or the form was completed after the rent was paid. Questioned Costs: Unknown Cause: Procedures were not in place to fill out the rent calculation form. Effect: Rent paid may not be reasonable or in line with requirements. Repeat finding: Not a repeat finding Recommendation: CLA recommends that a policy is put in place to document the rent reasonableness procedures as well as documented review. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Recommendation: CLA recommends that a policy is put in place to document the rent reasonableness procedures as well as documented review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Rent Reasonableness Policy was updated in July 2025 to clearly require that verification be completed and documented before any rent payment. Each unit must now be compared to at least two similar unassisted units using reliable public sources, with supporting evidence uploaded to the participant’s electronic file. A comprehensive review of all ROOF Project files for placements made after July 1, 2023, has been completed, and all missing documentation has been corrected. Staff received refresher training in August 2025, and all housing specialists are required to complete a HUD Exchange training on rent reasonableness standards by November 2025. Name(s) of the contact person(s) responsible for corrective action: Jacqueline Jones, Director Family Supportive Housing Planned completion date for corrective action plan: July 2025

Categories

Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1164522 2025-002
    Material Weakness Repeat
  • 1164524 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $1.17M
14.267 CONTINUUM OF CARE PROGRAM $772,744
93.600 HEAD START $241,200
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $186,560
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $108,041
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $89,741
10.558 CHILD AND ADULT CARE FOOD PROGRAM $70,929
93.788 OPIOID STR $49,005
14.235 SUPPORTIVE HOUSING PROGRAM $40,000
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $32,448
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $17,852
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $4,474