FAC Explorer

Finding 24617 (2022-012)

Material Weakness Repeat Finding
Requirement
BE
Questioned Costs
$1
Year
2022
Accepted
2023-03-30
Audit: 22749
Organization: The City of New York (NY)
Auditor: Grant Thornton LLP

AI Summary

  • Core Issue: HRA failed to consistently document and review tenant eligibility and payment calculations for rental assistance, leading to potential noncompliance with federal requirements.
  • Impacted Requirements: Compliance with federal guidelines on allowable costs, eligibility determination, and internal controls was not met, resulting in questioned costs of $18,240.
  • Recommended Follow-Up: HRA should enhance internal controls by implementing a review checklist to ensure all eligibility criteria are met and that supervisory approvals are documented before processing payments.

Finding Text

New York City Human Resources Administration (?HRA?) Finding #: 2022-012 Funding Year(s): 10/19/2017-9/1/2025 HOME Investment Partnerships Program (FAL #14.239) Contract Numbers: M-17-MC-36-0204 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Allowable Costs and Eligibility - Material Noncompliance and Internal Control (Material Weakness) Criteria: In accordance with 23 CFR sections 1.9, 172.11(a), 420.113(a), and 630.106(a), costs incurred under federal awards are considered allowable and reimbursable when such costs are deemed necessary and reasonable; incurred subsequent to the date of authorization to proceed and in accordance with the conditions contained in the project agreement and the plans specifications; and, not included as costs used to meet cost sharing or matching requirements, among other things. As stipulated by 24 CFR ?92.209, tenant-based rental assistance (?TBRA?) may only be provided to very low- and low-income families. The participating jurisdiction must determine that the family is very low- or low-income before the assistance is provided. During the period of assistance, the participating jurisdiction must annually determine that the family continues to be low-income. Also, the maximum monthly assistance that a participating jurisdiction may pay to, or on behalf of, a family may not exceed the difference between a rent standard for the unit size established by the participating jurisdiction and 30% of the family's monthly adjusted income. Additionally, the participating jurisdiction must disapprove a lease if the rent is not reasonable, based on rents that are charged for comparable unassisted rental units. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: The New York City Human Resources Administration (?HRA?) utilizes the Current System to assess beneficiaries? eligibility to receive tenant based rental assistance through the HOME Investment Partnerships Program (?HOME?). To assess eligibility, HRA program staff obtain income supporting documentation to determine if the household met the low-income requirement and to calculate the maximum subsidy amount to be paid by HRA. Additionally, a rent reasonableness valuation is performed which compares the current beneficiary?s rent to other rents charged for comparable units to ensure reasonableness. Upon the completion of the eligibility determination by an HRA staff member, a designated program supervisor reviews and approves the eligibility determination, subsidy amount, and tenant share within Current. We selected a non-statistical sample of forty (40) rental assistance payments made on behalf of tenants during fiscal 2022 and found that twenty-two (22) of the selections had errors as follows: ? For thirteen (13) of the twenty-two (22) selections, HRA was not able to provide documentation to support the participant?s annual income. ? For nine (9) of the twenty-two (22) selections , HRA was also not able to provide the HOME TBRA Certification Information Form, which is utilized to calculate and support HRA?s share of the monthly rent to be paid on behalf of the participant. ? For fourteen (14) of the twenty-two (22) selections, HRA was not able to provide documentation to support that a rent reasonableness assessment was performed. ? For four (4) of the twenty-two (22) selections, it was noted that HRA?s share of monthly rent was determined to be $1,729, $1,778, $1,544, and $235, respectively. However, due to manual input errors, the amounts actually paid on behalf of these tenants were $1,780, $1,762, $1,534, and $176, respectively. ? For one (1) of the twenty-two (22) selections, HRA was unable to provide documentation to support that the eligibility determination and the related calculation was properly reviewed and approved by a supervisor. Total TBRA payments charged to the grant were $5,533,841 and total TBRA benefits subjected to testing were $54,915. Cause/Effect: While HRA has a process in place to assess the eligibility of tenants and calculate the monthly TBRA payments on behalf of those tenants to ensure allowability of costs incurred, a comprehensive review was not consistently performed and documented to ensure the appropriate evidence and related approvals were maintained to support those determinations and calculations. As a result, costs were incurred on behalf of certain tenants that may not have met the eligibility requirements, or an incorrect amount may have been paid on their behalf. Questioned Costs: Known questioned costs totaled $18,240. Identification as a Repeat Finding: This finding is similar to finding #2021-011, included on pages 249 and 250 of the Fiscal 2021 Single Audit report. Recommendation: We recommend that HRA strengthen their internal controls governing the eligibility determination process, including creating a comprehensive review checklist to ensure each tenant meets every eligibility requirement and HRA?s portion of the TBRA payments are properly calculated, and that appropriate supervisory review and approval is consistently performed and documented prior to processing payments and charging costs to the grant.

Corrective Action Plan

Finding No. 2022-012 Department(s) New York City Human Resources Administration Program(s) Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s) Response: ? HRA agrees that the Agency had challenges in retaining some recertification documentation during the COVID Public Health crisis when staff were working from home and then ultimately leaving the Agency prior to the return to office. ? The identified HOME TBRA tenants had been originally found eligible over five years ago and have been recertified annually every year following. ? This FY22 audit was conducted on the heels of the FY21 audit where the finding was the same and the recommended Corrective Action was the development of a Quality Assurance Checklist due by November 2022 and ongoing. ? HRA agrees to strengthen internal controls and have created and implemented a Quality Assurance Tool that ensure eligibility is accurately assessed, allowable cost is correctly calculated and appropriate evidence (i.e. Recertification Information Form, Proof of Income, Rent Reasonableness Information, Passed Inspection, Landlord Packet, Client Packet, RAC, Tenant Breakdown) that support annual approval is maintained. Also, the payment system already fully requires supervisor approval before annual payments can be set up. Absolutely no payment can go out without supervisor approval. Corrective Actions: ? Strengthen internal governance and future compliance. ? Hire an Executive Director for the TBRA ? Create and implement a Quality Assurance tool that includes information that supports eligibility. ? Provide refresher training for staff involved with TBRA. Anticipated Completion Date May 2023 and ongoing Person(s) Responsible for Implementation Dori Hopkins-Figeroux Director, TBRA (929) 252-6089 Dwana Abraham Assistant Deputy Commissioner (929) 221-6726

Categories

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility Material Weakness

Other Findings in this Audit

  • 24614 2022-003
    -
  • 24615 2022-008
    -
  • 24616 2022-011
    Material Weakness
  • 24618 2022-007
    Material Weakness
  • 24619 2022-013
    Material Weakness Repeat
  • 24620 2022-014
    Significant Deficiency
  • 24621 2022-009
    Significant Deficiency
  • 24622 2022-010
    Significant Deficiency
  • 24623 2022-001
    - Repeat
  • 24624 2022-001
    - Repeat
  • 24625 2022-001
    - Repeat
  • 24626 2022-001
    - Repeat
  • 24627 2022-001
    -
  • 24628 2022-001
    - Repeat
  • 24629 2022-016
    Significant Deficiency Repeat
  • 24630 2022-016
    Significant Deficiency Repeat
  • 24631 2022-016
    Significant Deficiency Repeat
  • 24632 2022-016
    Significant Deficiency Repeat
  • 24633 2022-006
    -
  • 24634 2022-015
    Material Weakness
  • 24635 2022-004
    -
  • 24636 2022-005
    Significant Deficiency
  • 24637 2022-002
    - Repeat
  • 601056 2022-003
    -
  • 601057 2022-008
    -
  • 601058 2022-011
    Material Weakness
  • 601059 2022-012
    Material Weakness Repeat
  • 601060 2022-007
    Material Weakness
  • 601061 2022-013
    Material Weakness Repeat
  • 601062 2022-014
    Significant Deficiency
  • 601063 2022-009
    Significant Deficiency
  • 601064 2022-010
    Significant Deficiency
  • 601065 2022-001
    - Repeat
  • 601066 2022-001
    - Repeat
  • 601067 2022-001
    - Repeat
  • 601068 2022-001
    - Repeat
  • 601069 2022-001
    -
  • 601070 2022-001
    - Repeat
  • 601071 2022-016
    Significant Deficiency Repeat
  • 601072 2022-016
    Significant Deficiency Repeat
  • 601073 2022-016
    Significant Deficiency Repeat
  • 601074 2022-016
    Significant Deficiency Repeat
  • 601075 2022-006
    -
  • 601076 2022-015
    Material Weakness
  • 601077 2022-004
    -
  • 601078 2022-005
    Significant Deficiency
  • 601079 2022-002
    - Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.88B
84.425 Education Stabilization Fund $1.47B
84.010 Title I Grants to Local Educational Agencies $722.16M
14.871 Section 8 Housing Choice Vouchers $551.30M
14.218 Community Development Block Grants/entitlement Grants $391.16M
84.027 Special Education_grants to States $333.72M
93.575 Child Care and Development Block Grant $290.92M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $235.87M
93.667 Social Services Block Grant $205.88M
21.019 Coronavirus Relief Fund $195.45M
93.658 Foster Care_title IV-E $192.64M
97.067 Homeland Security Grant Program $175.17M
93.498 Provider Relief Fund $172.35M
93.268 Immunization Cooperative Agreements $152.20M
66.458 Capitalization Grants for Clean Water State Revolving Funds $106.36M
93.568 Low-Income Home Energy Assistance $102.99M
93.659 Adoption Assistance $76.55M
66.468 Capitalization Grants for Drinking Water State Revolving Funds $75.86M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $71.82M
66.482 Disaster Relief Appropriations Act (draa) Hurricane Sandy Capitalization Grants for Clean Water State Revolving Funds $67.62M
20.507 Federal Transit_formula Grants $64.90M
93.563 Child Support Enforcement $62.40M
93.600 Head Start $62.00M
10.555 National School Lunch Program $56.30M
84.367 Improving Teacher Quality State Grants $56.03M
84.424 Student Support and Academic Enrichment Program $54.77M
93.461 Covid-19 Testing for the Uninsured $53.16M
14.239 Home Investment Partnerships Program $49.00M
14.267 Continuum of Care Program $44.70M
16.922 Equitable Sharing Program $44.43M
14.241 Housing Opportunities for Persons with Aids $40.46M
93.767 Children's Health Insurance Program $39.68M
84.365 English Language Acquisition State Grants $33.89M
10.558 Child and Adult Care Food Program $29.99M
93.569 Community Services Block Grant $29.77M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $28.44M
17.259 Wia Youth Activities $21.62M
32.009 Emergency Connectivity Fund Program $19.78M
93.556 Promoting Safe and Stable Families $17.56M
17.258 Wia Adult Program $17.24M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $17.00M
20.527 Public Transportation Emergency Relief Program $16.47M
84.287 Twenty-First Century Community Learning Centers $15.99M
93.958 Block Grants for Community Mental Health Services $14.85M
84.048 Career and Technical Education -- Basic Grants to States $13.53M
21.023 Emergency Rental Assistance Program $13.40M
17.278 Wia Dislocated Worker Formula Grants $13.17M
93.069 Public Health Emergency Preparedness $12.68M
14.231 Emergency Solutions Grant Program $12.62M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $12.22M
21.016 Equitable Sharing $11.96M
84.173 Special Education_preschool Grants $11.75M
97.075 Rail and Transit Security Grant Program $11.27M
93.090 Guardianship Assistance $10.97M
84.165 Magnet Schools Assistance $10.20M
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $10.15M
93.053 Nutrition Services Incentive Program $9.99M
97.056 Port Security Grant Program $9.60M
66.483 Disaster Relief Appropriations Act (draa) Hurricane Sandy Capitalization Grants for Drinking Water State Revolving Funds $9.54M
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $8.99M
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $7.24M
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $7.16M
64.024 Va Homeless Providers Grant and Per Diem Program $6.48M
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $5.96M
97.044 Assistance to Firefighters Grant $5.56M
97.042 Emergency Management Performance Grants $5.34M
84.041 Impact Aid $4.62M
16.004 Law Enforcement Assistance_narcotics and Dangerous Drugs Training $4.52M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $4.50M
93.994 Maternal and Child Health Services Block Grant to the States $4.44M
93.052 National Family Caregiver Support, Title Iii, Part E $4.41M
93.262 Occupational Safety and Health Program $4.32M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $4.25M
84.181 Special Education-Grants for Infants and Families $4.16M
84.002 Adult Education - Basic Grants to States $4.06M
93.914 Hiv Emergency Relief Project Grants $3.81M
97.106 Securing the Cities Program $3.72M
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $3.69M
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $3.69M
17.235 Senior Community Service Employment Program $2.98M
84.196 Education for Homeless Children and Youth $2.91M
10.664 Cooperative Forestry Assistance $2.83M
84.374 Teacher Incentive Fund $2.77M
93.150 Projects for Assistance in Transition From Homelessness (path) $2.51M
97.091 Homeland Security Biowatch Program $2.39M
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $2.28M
97.039 Hazard Mitigation Grant $2.25M
16.034 Coronavirus Emergency Supplemental Funding Program $2.23M
14.269 Hurricane Sandy Community Development Block Grant Disaster Recovery Grants (cdbg-Dr) $2.16M
10.923 Emergency Watershed Protection Program $2.13M
93.889 National Bioterrorism Hospital Preparedness Program $2.07M
16.710 Public Safety Partnership and Community Policing Grants $2.03M
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $1.92M
93.778 Medical Assistance Program $1.91M
14.879 Mainstream Vouchers $1.57M
93.924 Ryan White Hiv/aids Dental Reimbursement and Community Based Dental Partnership Grants $1.57M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $1.55M
14.896 Family Self-Sufficiency Program $1.49M
94.011 Foster Grandparent Program $1.47M
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $1.44M
66.437 Long Island Sound Program $1.42M
10.582 Fresh Fruit and Vegetable Program $1.35M
93.604 Assistance for Torture Victims $1.33M
93.944 Human Immunodeficiency Virus (hiv)/acquired Immunodeficiency Virus Syndrome (aids) Surveillance $1.30M
20.205 Highway Planning and Construction $1.27M
93.350 National Center for Advancing Translational Sciences $1.21M
17.245 Trade Adjustment Assistance $1.21M
93.817 Hospital Preparedness Program (hpp) Ebola Preparedness and Response Activities $1.19M
93.137 Community Programs to Improve Minority Health Grant Program $1.01M
14.235 Supportive Housing Program $968,000
93.070 Environmental Public Health and Emergency Response $911,000
93.834 Capacity Building Assistance (cba) for High-Impact Hiv Prevention $861,000
20.200 Highway Research and Development Program $845,000
15.153 Hurricane Sandy Disaster Relief ? Coastal Resiliency Grants. $798,000
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $798,000
93.253 Poison Center Support and Enhancement Grant $787,000
16.543 Missing Children's Assistance $705,000
14.905 Lead Hazard Reduction Demonstration Grant Program $697,000
93.059 Training in General, Pediatric, and Public Health Dentistry $687,000
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $667,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $635,000
20.600 State and Community Highway Safety $621,000
93.779 Centers for Medicare and Medicaid Services (cms) Research, Demonstrations and Evaluations $617,000
20.521 New Freedom Program $612,000
93.940 Hiv Prevention Activities_health Department Based $600,000
93.197 Childhood Lead Poisoning Prevention Projects_state and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $557,000
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $539,000
93.576 Refugee and Entrant Assistance_discretionary Grants $535,000
10.565 Commodity Supplemental Food Program $517,000
93.825 National Ebola Training and Education Center (netec) $515,000
84.351 Arts in Education $512,000
93.103 Food and Drug Administration_research $492,000
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $468,000
17.277 Workforce Investment Act (wia) National Emergency Grants $437,000
93.316 Public Health Preparedness and Response Science, Research, and Practice $409,000
20.500 Federal Transit_capital Investment Grants $403,000
93.071 Medicare Enrollment Assistance Program $398,000
16.814 Northern Border Prosecution Initiative Program $393,000
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $386,000
93.242 Mental Health Research Grants $385,000
16.825 Smart Prosecution Initiative $383,000
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $378,000
12.002 Procurement Technical Assistance for Business Firms $374,000
93.926 Healthy Start Initiative $369,000
16.575 Crime Victim Assistance $361,000
93.270 Adult Viral Hepatitis Prevention and Control $343,000
93.217 Family Planning_services $342,000
16.582 Crime Victim Assistance/discretionary Grants $331,000
16.320 Services for Trafficking Victims $320,000
93.939 Hiv Prevention Activities_non-Governmental Organization Based $320,000
93.747 Elder Abuse Prevention Interventions Program $299,000
97.047 Pre-Disaster Mitigation $295,000
93.991 Preventive Health and Health Services Block Grant $280,000
93.136 Injury Prevention and Control Research and State and Community Based Programs $271,000
93.226 Research on Healthcare Costs, Quality and Outcomes $267,000
93.279 Drug Abuse and Addiction Research Programs $266,000
93.686 Ending the Hiv Epidemic: A Plan for America Ryan White Hiv/aids Program Parts A and B (b) $251,000
93.310 Trans-Nih Research Support $247,000
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $246,000
93.191 Graduate Psychology Education Program and Patient Navigator and Chronic Disease Prevention Program $243,000
16.588 Violence Against Women Formula Grants $232,000
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $228,000
10.310 Agriculture and Food Research Initiative (afri) $213,000
10.580 Supplemental Nutrition Assistance Program, Process and Technology Improvement Grants $207,000
93.558 Temporary Assistance for Needy Families $188,000
10.553 School Breakfast Program $179,000
16.735 Prea Program: Demonstration Projects to Establish 'zero Tolerance' Cultures for Sexual Assault in Correctional Facilities $179,000
93.365 Sickle Cell Treatment Demonstration Program $172,000
16.838 Comprehensive Opioid Abuse Site-Based Program $165,000
93.307 Minority Health and Health Disparities Research $157,000
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $156,000
10.559 Summer Food Service Program for Children $155,000
10.927 Emergency Watershed Protection Program - Disaster Relief Appropriations Act $146,000
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs $143,000
93.884 Grants for Primary Care Training and Enhancement $140,000
93.478 Preventing Maternal Deaths: Supporting Maternal Mortality Review Committees (b) $138,000
84.042 Trio_student Support Services $130,000
93.761 Evidence-Based Falls Prevention Programs Financed Solely by Prevention and Public Health Funds (pphf) $127,000
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $122,000
94.006 Americorps $119,000
45.024 Promotion of the Arts_grants to Organizations and Individuals $118,000
96.006 Supplemental Security Income $106,000
16.833 National Sexual Assault Kit Initiative $104,000
93.788 Opioid Str $92,000
16.741 Dna Backlog Reduction Program $91,000
14.276 Youth Homelessness Demonstration Program $80,000
93.165 Grants to States for Loan Repayment $80,000
66.461 Regional Wetland Program Development Grants $74,000
97.025 National Urban Search and Rescue (us&r) Response System $64,000
66.472 Beach Monitoring and Notification Program Implementation Grants $60,000
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $53,000
93.855 Allergy, Immunology and Transplantation Research $45,000
10.935 Urban Agriculture and Innovative Production $44,000
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $42,000
12.620 Troops to Teachers Grant Program $31,000
81.086 Conservation Research and Development $22,000
93.837 Cardiovascular Diseases Research $19,000
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $18,000
93.361 Nursing Research $17,000
93.732 Mental and Behavioral Health Education and Training Grants $15,000
93.838 Lung Diseases Research $15,000
93.113 Environmental Health $13,000
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $13,000
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $13,000
97.045 Cooperating Technical Partners $13,000
47.070 Computer and Information Science and Engineering $10,000
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $10,000
97.065 Homeland Security Advanced Research Projects Agency $9,000
93.434 Every Student Succeeds Act/preschool Development Grants $7,000
20.520 Paul S. Sarbanes Transit in the Parks $6,000
16.304 Law Enforcement Assistance_national Crime Information Center $5,000
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $3,000
20.933 National Infrastructure Investments $2,000
84.377 School Improvement Grants $0
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $0