Finding 1174797 (2024-001)

Finding 2024-001 Internal Control Over Compliance - Eligibility Program: Rural Rental Housing Loans Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.415 Internal Control Area: Internal Control Over Compliance – Eligibility Condition: The entity did not provide adequate documentation to the auditors to support eligibility determinations for certain tenants participating in the Rural Rental Housing Loans program. As a result, the auditors could not opine on compliance with this federal grant as it applies to tenant eligibility. Criteria: Uniform Guidance (§200.303) requires non-federal entities to establish and maintain effective internal control over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Effective internal control over eligibility with this federal award includes procedures for verifying, documenting, reviewing, and retaining tenant eligibility information. Cause: The deficiency appears to be due to insufficient internal controls over the retention of adequate documentation to support eligibility determinations made by management. Effect: Because internal controls over eligibility were not operating effectively, there was inadequate documentation available to provide to the auditors for testing of such eligibility determinations. Recommendation: We recommend that management strengthen internal controls over eligibility by establishing formal procedures for implementing supervisory review of tenant files, and ensuring eligibility documentation is retained in accordance with program requirements. Management’s Response and Corrective Action: Management agrees with this finding and will implement procedures to ensure that all supporting documentation related to tenant eligibility is retained and easily retrievable.