Finding 33305 (2022-001)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2022

Accepted

2023-09-14

Audit: 29591

Organization: The Ministry of Caring, INC (DE)

Auditor: Belfint Lyons & Shuman O A

AI Summary

Core Issue: One tenant's file lacked documentation for the occupancy charge, violating Title 24 CFR Part 578 requirements.
Impacted Requirements: Recipients must not charge more than 30% of adjusted income or 10% of gross income and must document income annually.
Recommended Follow-Up: Implement procedures to ensure accurate rent calculations and proper documentation for all tenants charged occupancy fees.

Finding Text

Criteria: The requirements of Title 24 U.S. Code of Federal Regulations (CFR) Part 578, Continuum of Care Program, Subpart F, Program Requirements indicate that recipients are not required to impose occupancy charges on program participants as a condition of residing in the housing. However, if occupancy charges are imposed, they may not exceed the highest of 30% of the family?s monthly adjusted income or 10% of the family?s monthly gross income. Additionally, the requirements indicate that recipients must maintain documentation to support program participants? income if occupancy charges are imposed, and that income must be reexamined at least annually to determine that the program participant is being charged the correct rent amount. Condition: Our testing included a sample of 11 tenants from seven different programs. Audit procedures determined one instance where a tenant?s file from Nazareth House Holistic Housing did not contain documentation of the annual rent calculation to support the occupancy charge on file. Cause: Oversight of program compliance requirements by the former program employee. Effect: One tenant?s file did not contain all the required documentation to support the occupancy charge imposed. Recommendation: We recommend the Organization implement procedures to ensure that shelters which choose to charge rent are calculating rent and maintaining the proper documentation based on the criteria in Title 24 CFR 578.

Corrective Action Plan

Corrective Action Plan: Initial and subsequent rent calculation will be completed by the Family Resource Coordinator. Family Resource Coordinator will submit to Program Director for review and sign off that it?s complete. Program Director will submit to grant compliance staff who will review and confirm accuracy (and track on spreadsheet, additional step). Grant compliance staff will submit to Deputy Director of Programs tracking spreadsheet to confirm completion (new step). Will review rent calculation with all staff who does rent calculation at a minimum of six times each year. Contact Person Responsible for Corrective Action: John Bates, Deputy Director of Programs Anticipated Completion Date of Corrective Action: To begin immediately.

Other Findings in this Audit

33306 2022-002

Significant Deficiency
609747 2022-001

Significant Deficiency Repeat
609748 2022-002

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
14.267	Continuum of Care Program	$1.22M
14.275	Housing Trust Fund	$500,000
93.569	Community Services Block Grant	$335,804
10.558	Child and Adult Care Food Program	$139,182
93.747	Elder Abuse Prevention Interventions Program	$80,000
97.024	Emergency Food and Shelter National Board Program	$76,766
14.241	Housing Opportunities for Persons with Aids	$50,220
14.231	Emergency Solutions Grant Program	$27,824
14.218	Community Development Block Grants/entitlement Grants	$20,000
94.006	Americorps	$10,390