Finding 1241548 (2024-007)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2026-11-02

AI Summary

  • Core Issue: Missing signed sublease and master lease agreements in 7 out of 21 tenant files could affect the verification of reasonable rent payments.
  • Impacted Requirements: While no compliance issues were found, the lack of documentation raises concerns about ensuring rent aligns with local market rates.
  • Recommended Follow-Up: Implement procedures to guarantee all tenant files contain necessary documentation, and continue using checklists and periodic reviews to maintain compliance.

Finding Text

Criteria: When grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. As part of their internal control policies, the Organization requires that the following documents are included within the tenant file: signed sublease agreement between the Organization and member/tenant and signed master lease agreement between the tenant and landlord. Condition: We were unable to obtain both the signed sublease agreement and master lease agreement for 7 of the 21 tenant files selected for testing. Of those 7 files, there was 1 file where we were unable to obtain either the signed sublease agreement or master lease agreement. The Compliance Supplement does not specify that lease agreements must be examined to verify the rent paid is reasonable in relation to rents being charged in the area for comparable space. In addition, allowable costs/cost principles and activities allowed or unallowed is not applicable to the Continuum of Care Program. Therefore, no instances of noncompliance were identified. Cause: There was a change in personnel within the housing department. Also, the department relocated to a new building during a prior fiscal year and was still getting organized. Effect: While we were able to validate for our selections the rent paid was reasonable in relation to rents being charged in the area for a comparable space for the population tested, there is the potential that the amount being paid on behalf of the tenant is not in line with the agreed upon rate if lease agreements are not retained. Repeat Finding: Prior year finding 2023-006. Recommendation: The Organization should implement procedures to ensure that tenant files include all of the required documentation to support that the rent paid is reasonable in relation to rents being charged in the area for comparable space. Response: Beginning in FY25, the Organization implemented standardized housing compliance procedures, including the use of checklists during lease execution and annual recertification to ensure required master leases, subleases, and supporting documentation are obtained and maintained. Management has also strengthened document retention practices and periodic file reviews to promote complete and accessible tenant files.

Corrective Action Plan

Corrective Action Planned: Beginning in FY25, the Organization implemented standardized housing compliance procedures, including the use of checklists during lease execution and annual recertification to ensure required master leases, subleases, and supporting documentation are obtained and maintained. Management has also strengthened document retention practices and periodic file reviews to promote complete and accessible tenant files. Management’s Response: Management agrees with the finding. Historical personnel turnover and prior documentation retention practices contributed to incomplete tenant files. Since FY25, enhanced procedures and oversight have been implemented to improve documentation compliance and retention. The audit identified no instances of noncompliance and confirmed that rents tested were reasonable. Management's corrective actions are focused on ensuring required supporting documentation is consistently maintained and readily available for future review.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1241535 2024-006
    Material Weakness Repeat
  • 1241536 2024-006
    Material Weakness Repeat
  • 1241537 2024-006
    Material Weakness Repeat
  • 1241538 2024-006
    Material Weakness Repeat
  • 1241539 2024-006
    Material Weakness Repeat
  • 1241540 2024-006
    Material Weakness Repeat
  • 1241541 2024-006
    Material Weakness Repeat
  • 1241542 2024-006
    Material Weakness Repeat
  • 1241543 2024-007
    Material Weakness Repeat
  • 1241544 2024-007
    Material Weakness Repeat
  • 1241545 2024-007
    Material Weakness Repeat
  • 1241546 2024-007
    Material Weakness Repeat
  • 1241547 2024-007
    Material Weakness Repeat
  • 1241549 2024-008
    Material Weakness Repeat
  • 1241550 2024-008
    Material Weakness Repeat
  • 1241551 2024-008
    Material Weakness Repeat
  • 1241552 2024-008
    Material Weakness Repeat
  • 1241553 2024-008
    Material Weakness Repeat
  • 1241554 2024-008
    Material Weakness Repeat
  • 1241555 2024-009
    Material Weakness Repeat
  • 1241556 2024-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $2.27M
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $1.12M
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $655,978
14.267 CONTINUUM OF CARE PROGRAM $263,134
93.788 OPIOID STR $8,252