Finding 30883 (2022-011)

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

AI Summary

  • Core Issue: Payments were made to related parties without proper documentation, raising concerns about compliance and business purpose.
  • Impacted Requirements: Internal controls failed to ensure sufficient evidence for expenses, leading to a lack of compliance with grant requirements.
  • Recommended Follow-Up: Implement a review process to ensure procedures are followed and deficiencies are detected promptly.

Finding Text

2022-11 Continuum of Care Program ? Assistance Listing No. 14.267, Grant No. FL0825L4H052000, Grant Period ? April 1, 2021 ? March 1,2021 (Non-COVID) Condition: As described in Finding 2022-3 and 2022-10 above, payments were made to related parties for which there was no supporting documentation. We requested but were not provided documentation, such as invoices or contracts to support expenditures. Although we were able to verify that the checks were made payable to the vendor recorded in the accounting records, we could not determine that the expenditure served a valid business purpose and complied with grant or contract requirements. Criteria: Internal controls should be in place that provide reasonable assurance that sufficient appropriate evidence to document the expenses. Cause: Procedures were not followed, and the deficiency was not detected on a timely basis. Effect: Because of the failure to follow procedures, a material amount of expenses was not documented. Context: 13 disbursements totaling $38,400 made through March 23, 2023. Recommendation: Procedures should be followed, and a review process should be implemented to provide assurance that failure to follow procedures is detected on a timely basis. TOTAL QUESTIONED COSTS FOR EMERGENCY SOLUTIONS GRANT PROGRAM ? Assistance Listing No. 14.267, Grant No. FL0825L4H052000 - $38,400 ALL PROGRAMS TOTAL QUESTIONED COSTS $1,201,076.09

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 Internal Control / Segregation of Duties

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