Finding 30876 (2022-004)

Material Weakness
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-06-20

AI Summary

  • Core Issue: Missing documentation for grant expenditures raises concerns about eligibility and compliance.
  • Impacted Requirements: Costs must be supported by adequate documentation, including contracts, invoices, and timesheets.
  • Recommended Follow-Up: The Alliance should explore ways to retrieve the missing documentation for questioned expenses totaling $1,143,058.77.

Finding Text

2022-4 Emergency Solutions Grant Program ? Assistance Listing No. 14.231, Grant No. APZ11, Grant Period ? Year Ended June 30, 2022, Covid Grants Material Weakness - Condition: As discussed in Finding Nos. 2022-1 and 2022-2, supporting documentation for grant expenditures was not located for these grants. Criteria: To be eligible for consideration as an allowable activity and be classified as an allowable cost, the cost must be adequately documented. Documentation should include contracts, invoices or receipts, timesheets supporting personnel charges, and a Purchase Request Form (PRF). Cause: Procedures are in place for supervisory approval of expenses and supporting documentation before assistance is authorized but documentation was apparently not filed correctly and may not have been retained. Effect: The cost of assistance may be disallowed. Context: Our review disclosed the following: ? For 5 of the 30 transactions tested, the expenses were adequately documented to support the fact that the activities were allowable. Although requested, documentation was not available for the other 25 test items totaling $985,309.26. ? Expenses totaling $1,143,058.77 were not adequately documented. For the 5 transactions for which documentation was not available, totaling $157,749.51, our review disclosed that there were no invoices or receipts from subrecipients who provided services to clients or PRF required by HHA procedures. Although requested, documentation was not available for 25 transactions totaling $985,308.26. Recommendation: The Alliance should consider options for obtaining documentation for the expenses for which supporting documentation could not be located. TOTAL QUESTIONED COSTS FOR EMERGENCY SOLUTIONS GRANT PROGRAM ? Assistance Listing No. 14.231, Grant No. APZ11 - $1,143,058.77 (included in Questioned cost of 2022-6 below)

Corrective Action Plan

Views of Responsible Official: Current management indicated that the former Executive Director of HHA, former Finance Director of HHA, and a former employee were employed by HHA, and the former Executive Director and Finance Director controlled all aspects of HHA?s management and finances during the relevant audited period. The former Executive Director?s employment with HHA was terminated on October 10, 2022. The former Finance Director?s employment with HHA was terminated on October 20, 2022. The third employee?s employment with HHA was terminated on October 11, 2022. Additionally, all but two of the Board of Directors who served during the period in which the irregularities occurred have been replaced. HHA appointed the current Executive Director, Crystal Harrison (?Executive Director?), on October 10, 2022, as Interim Executive Director and promoted her to the position of Executive Director on October 26, 2022. The current Executive Director has diligently searched for all documents and records for all purchases, expenses, and cash distributions at issue during the former Executive Director?s tenure as Executive Director. However, no such documents or records were located on site at HHA?s offices or on HHA?s computers or devices. In early April 2023, HHA?s attorney served the former Executive Director, former Finance Director, and former employee with a demand to produce the missing documents and records but each responded that they had no such documents or records in their possession. Unfortunately, because of the actions of the former Executive Director, Finance Director, and employee, HHA lacks sufficient operating funds to pursue a civil suit to recover the losses caused by these former employees. Further, HHA?s errors and omissions insurance policy only covers third-party claims. As such, HHA has directed its attorney to take all appropriate action to pursue criminal charges of grand theft/embezzlement and fraud against these former employees upon completion of the audit. HHA?s attorney has already reached out to law enforcement to begin this process. Once the formal criminal complaint is filed, law enforcement will be empowered to subpoena the missing documents and records (should said documents and records still exist) from the former employees, as well as their banking and financial records (including tax returns) to track the suspicious expenses and cash distributions at issue. The current Executive Director, with the full support of HHA?s Board, is committed to taking all action necessary to ensure compliance with the rules and procedures already in place regarding expenses and cash distributions, as well as to enact new enhanced procedures for periodic reviews of these procedures to timely detect deficiencies and ensure compliance going forward. In addition, the current Executive Director will implement a process to ensure that backup records are maintained electronically as well as in a paper form.

Categories

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.231 Emergency Solutions Grant Program $3.04M
14.267 Continuum of Care Program $330,170
93.558 Temporary Assistance for Needy Families $36,860
14.218 Community Development Block Grants/entitlement Grants $8,304