Finding Text
Criteria: HUD’s Continuum of Care program (ALN 14.267) requires recipients to maintain complete and accurate documentation to support participant eligibility and rental assistance in accordance with 24 CFR §578.103. Tenant-based rental assistance must be supported by a valid lease between the participant and landlord in accordance with applicable housing requirements (including 24 CFR § 982.305 and 24 CFR §982.309, as applicable through program guidance). Required participant protections and disclosures, including those under the Violence Against Women Act (VAWA), must be provided and documented in accordance with 24 CFR § 5.2005 and 24 CFR § 5.2009. In addition, housing quality standards and environmental requirements, including inspections and lead-based paint disclosures, must be completed and documented prior to assistance in accordance with 24 CFR § 982.401 and 24 CFR § 35.92. Furthermore, in accordance with 2 CFR § 200.303, organizations must establish and maintain effective internal controls to ensure required documentation is obtained, reviewed, and retained prior to the disbursement of federal funds. Where utilities are paid as a supportive service under 24 CFR § 578.51, appropriate documentation, including participant consent, must be maintained. Conditions: Our testing of 18 tenant files identified multiple instances of missing or incomplete required documentation. Specifically, 1 file lacked an executed lease agreement, 3 files contained leases with terms less than one year, 2 files were missing required RAP forms with VAWA addenda, 1 file lacked inspection documentation, 1 file was missing a Form W-9, and 1 file did not include a required lead-based paint disclosure. Additionally, among 2 Permanent Supportive Housing tenant files tested, 1 file lacked a required Consent to Pay Utilities form. These results indicate that controls over required documentation are not consistently operating effectively. Cause and Effect: This condition appears to be due to inadequate internal controls and monitoring procedures to ensure that all required documentation is obtained, completed, and retained prior to the approval and disbursement of rental assistance. Specifically, staff did not consistently utilize a standardized checklist or review process to verify file completeness. We identified a significant deficiency in internal control over compliance related to required documentation. The absence of required documentation increases the risk of noncompliance with program requirements, potential disallowance of costs, and repayment of federal funds. No questioned costs were identified as a result of this condition. Recommendations: We recommend management strengthen controls over required documentation by implementing a standardized pre-approval checklist to ensure all required documentation is obtained and verified prior to disbursement of assistance. This should include, at a minimum, a fully executed lease (including verification of lease term), RAP agreement and VAWA documentation, inspection and housing quality documentation, Form W-9, and required lead-based paint disclosures. For supportive services such as utility payments, required participant consent documentation should be obtained and retained prior to payment. Additionally, management should implement a documented secondary review process and perform periodic quality control reviews to ensure ongoing compliance. Staff should be trained on documentation requirements and file completion standards.