Finding 35147 (2022-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-07-26

AI Summary

  • Core Issue: The City of South St. Paul lacks adequate internal controls for compliance with federal housing program requirements, leading to noncompliance in tenant placement.
  • Impacted Requirements: The deficiencies relate to the management of the waiting list and placement of tenants, violating federal special tests and provisions as outlined in 24 CFR 960.
  • Recommended Follow-Up: The City should enhance its internal control procedures and verify compliance with federal requirements to ensure proper tenant placement and avoid future violations.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCES OF NONCOMPLIANCE ? U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT PUBLIC AND INDIAN HOUSING ? ALN 14.850 2022-001 Internal Control and Compliance With Special Tests and Provisions Requirements Criteria ? 24 CFR ? 960. Management is responsible for establishing and maintaining effective internal control over compliance with requirements applicable to federal programs, including special tests and provisions requirements applicable to the Public and Indian Housing federal program. Condition ? During our audit, we noted that the City of South St. Paul, Minnesota (the City) did not have sufficient controls in place within the Public and Indian Housing federal program to assure compliance with federal special tests and provisions requirements, which resulted in noncompliance. The City did not have proper controls in place regarding the waiting list to verify new tenants were placed into housing, based on approved policies. Questioned Costs ? Not applicable. Context ? The condition applies to special tests and provisions requirements as noted above. Six of forty individuals added to the waiting list selected for testing were not added in accordance with the City?s policy. One of ten individuals placed into housing from the waiting list selected for testing was not placed in accordance with the City?s policy. This was not a statistically valid sample. Cause ? This was an oversight by city personnel. Repeat Finding ? This is a current year and prior year finding. Effect ? Noncompliance with the special tests and provisions requirements could be viewed as a violation of the award agreement and result in tenants being placed into housing incorrectly based on their rank on the waiting list. Recommendation ? We recommend that the City review its internal control procedures relating to special tests and provisions requirements for all federal programs. The City should verify compliance with federal special tests and provisions procedures, including the waiting list, to ensure tenants are being properly placed into housing. View of Responsible Official and Planned Corrective Actions ? The City agrees with the finding. The City has separately issued a Corrective Action Plan related to this finding.

Corrective Action Plan

2022-001 INTERNAL CONTROL AND COMPLIANCE WITH SPECIAL TESTS AND PROVISIONS REQUIREMENTS Summary of Finding The City of South St. Paul, Minnesota (the City) did not have proper controls in place regarding the waiting list to verify new tenants were placed into housing based on approved policies. During our audit, we noted that the City did not have sufficient controls in place within the Public and Indian Housing federal program to assure compliance with federal special tests and provisions requirements, which resulted in noncompliance. Corrective Action Plan Actions Planned ? The City has implemented new processes and procedures in 2023 which address this internal control and compliance finding to comply with Uniform Guidance in the future. Official Responsible ? The City?s Director of Economic and Community Development, Ryan Garcia. Planned Completion Date ? December 31, 2023. Disagreement With or Explanation of Finding ? The City agrees with this finding. Plan to Monitor ? The City?s Finance Director, Clara Hilger, will ensure the new process and procedures implemented improve internal controls and procedures in this area to ensure future federal grant compliance.

Categories

Internal Control / Segregation of Duties Special Tests & Provisions Significant Deficiency

Other Findings in this Audit

  • 611589 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
20.205 Highway Planning and Construction $5.10M
20.106 Airport Improvement Program $3.39M
14.850 Public and Indian Housing $938,416
14.170 Congregate Housing Services Program $204,792
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $31,528
20.600 State and Community Highway Safety $6,465
16.607 Bulletproof Vest Partnership Program $3,665