Finding Text
2025-007 Special Tests and Provisions - Rent Reasonableness U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Continuum of Care Program—Assistance Listing No. 14.267 Hennepin County Contract HS00001366; Grant Period – Year ended June 30, 2025 Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 578.51(g) requires recipients and subrecipients to determine whether rent charged for units receiving rental assistance is reasonable in relation to rents charged for comparable unassisted units, taking into consideration factors such as location, size, type, quality, amenities, facilities, and management and maintenance. Internal controls should be in place to document this determination. Condition: Documentation supporting one rent reasonableness determination could not be located for one direct program expense tested. Cause: Turnover within the program department during 2025 resulted in policies and procedures not being consistently followed. Effect: The rent reasonableness verification process is a key internal control to ensure rental assistance payments are reasonable and compliant with program requirements, which helps reduce the risk of fraud or mismanagement in the disbursement of Federal funds. Context: A statistically valid sample of 40 rental assistance payment transactions totaling $52,138 was selected for testing from a population of 393 transactions totaling $561,523. The audit identified one transaction totaling $1,300 that could not be substantiated with documentation supporting a rent reasonableness determination. Known Questioned Costs: None. The rental assistance payment reviewed was consistent with payments made for comparable transactions, and no concerns regarding allowability were identified. Identification of Repeat Finding: Not a repeat finding. Recommendation: We recommend that Agate Housing and Services, Inc. strengthen internal controls to ensure rent reasonableness determinations are completed and documented for all program participants prior to the disbursement of rental assistance funds. Management should implement a procedure to verify that required documentation is present before payment approval. Views of Responsible Officials and Planned Corrective Actions: Agate Housing and Services, Inc. agrees with the finding and is in the process of strengthening its controls over maintaining documentation of all rent reasonableness verifications.