Finding Text
Finding 2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Low-Income Home Energy Assistance ALN# 93.568 (Repeat 2022-015) US Department of Health and Human Services Passed through Oregon Housing and Community Services Federal Grant/Contract Number: 2302ORLIEA, 2202ORLIEA Grant period – 2022 & 2023 Criteria – Per the 2021-2023 Master Grant Agreement. Subgrantee shall, and shall cause and shall require its subrecipients by contract to administer the program in a manner satisfactory to OHCS and in compliance with all program requirements, including but not limited to the following terms and conditions: (4) Serve only households whose eligibility has been determined in compliance with program requirements. (8) Be responsible for maintaining an internal controls framework, satisfactory to OHCS, which assures compliance with program requirements. (11) Maintain other program records satisfactory to the department, which document, among other things, client eligibility requirements, receipt of allowable program services, termination of services and the basis for same, housing and income status of clients, administrative actions, contracts with subcontractors, review of subcontractor performance, action taken with respect to deficiency notices, and any administrative review proceedings. Such records shall be in substance and formatsatisfactory to the department. Condition – From the population of program beneficiaries, we selected a sample of 40 items, of which we identified 6 instances where client applications could not be produced. Cause – Supporting applications and required documentation were not retained by the Organization to substantiate eligibility and services provided. Effect – Applicants could receive improper benefit amounts based on eligibility criteria, excessive disbursements could be made, and a return of funds could be required to grantor. Questioned Costs – None Recommendation – Documentation should be prepared, reviewed, and retained to support the period of performance and earmarking. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.