Finding Text
Finding No. 2022-003 ? Lacking Certifications for Direct Assistance Provided to Individuals Federal Agency: Department of Education Department of the Treasury Federal Program: 84.235 Rehabilitation Services Demonstration and Training Program 21.023 Emergency Rental Assistance Type of Finding: Material Weakness in Internal Control over Compliance Finding: Internal control processes of over compliance did not ensure all client certification forms for federal assistance received were signed by tenants or completed in their entirety. Criteria: Per guidance in 2 CFR 200.302: The non-federal entity?s financial management systems, including records documenting compliance with federal statutes must be sufficient to permit the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the terms and conditions of the federal award. Condition and context: The Organization did not obtain a certification of actual final rent amounts received by landlords or tenants for total rent assistance payments received under the Emergency Rental Assistance program. The rent assistance accounting forms that were used by management included a tenant signature line, which would have provided a certification of the total amount of assistance provided, but no signatures were present on any of the forms tested. The Organization also did not obtain a certification acknowledging receipt of gift card funds from 12 of 25 gift card program recipients tested for the Rehabilitation Services Demonstration and Training Program. Sample Size and Population: We selected 6 rent assistance payments out of a population of 27 payments made under the Emergency Rental Assistance program during 2022. We selected 25 of 45 gift cards funded by the Rehabilitation Services Demonstration and Training Program during 2022. Cause: The Organization?s internal controls over obtaining certifications from federal award program recipients were not designed to ensure all recipients document their attestation as to the amount and date of funds received. Effect: The lack of controls over documentation of federal funds received could result in funds being distributed to ineligible individuals for federal assistance, or fraudulent use of funds. In addition, landlords receiving assistance for multiple months? future rents could charge tenants in duplicate for certain months? rents. Questioned Costs: $357 Recommendation: Management and those charged with governance should consider increasing the controls around the disbursement of funds to clients in the form of direct assistance via gift cards or check payments, and particularly obtaining and retaining signatures or adequate similar documentation directly from recipients for each disbursement received. Views of Management and Corrective Action Plan: Management?s response is reported in the ?Corrective Action Plan? at the end of this report. Contact Person: Ginger Kwan, Executive Director