Finding 1229424 (2023-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2026-09-11
Audit: 410819
Auditor: WIPFLI LLP

AI Summary

  • Core Issue: NIBC failed to maintain necessary documentation for eligibility determinations, impacting compliance with federal program requirements.
  • Impacted Requirements: Documentation control for eligibility under the Emergency Rental Assistance Program was inadequate, leading to a modified compliance opinion.
  • Recommended Follow-Up: NIBC should retain participant eligibility information or ensure the successor organization can provide it for future audits.

Finding Text

2023-003 Participant Eligibility Federal Program Information: Funding agency: Department of the Treasury, passed through the Battle Creek Community Foundation Title: Emergency Rental Assistance Program AL number: 21.023 Criteria or Specific Requirement: In order to support audits in accordance with Uniform Guidance, auditee's must maintain control over documentation to support program eligibility determinations. Condition: In our sample of 40 client files selected for eligibility testing, we were not able to obtain sufficient documentation to verify eligibility was properly determined for six of the files. NIBC represented that all client files were turned over to another nonprofit organization and are therefore no longer available. For context, NIBC provided the client files for audit before the files were turned over but did not include eligibility information at the time. Audit procedures did not occur to identify the missing information until after the files were turned over. Questioned Costs: None Effect: NIBC is not able to support eligibility determinations for client files that were turned over to another agency. As a result, the opinion on compliance is modified and a material weakness in internal control over compliance exists. Cause: The Emergency Rental Assistance Program had ended and NIBC no longer had a need to retain the files. Repeat: No Auditor's Recommendation: We recommend NIBC copy participant eligibility information for their own records to have available for audits or ensure the successor entity is able to provide eligibility information to NIBC auditors. View of Responsible Officials: Management agrees with the finding and has written a corrective action plan.

Corrective Action Plan

Management’s Response All participant eligibility documents are now in house and stored in a secure location on the NIBC server Contact Person Responsible for Corrective Action: Whitney Wardell Anticipated Completion Date: 7/1/2024

Categories

Eligibility Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1229422 2023-001
    Material Weakness Repeat
  • 1229423 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.023 COVID-19 EMERGENCY RENTAL ASSISTANCE PROGRAM $1.60M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $524,631
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $181,157
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $125,933
14.905 LEAD HAZARD REDUCTION DEMONSTRATION GRANT PROGRAM $70,035
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $18,920