Finding 389348 (2023-001)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-29

AI Summary

  • Core Issue: Incomplete documentation for tenant eligibility in the housing assistance program raises concerns about compliance.
  • Impacted Requirements: Missing key documents like landlord agreements and lease contracts hinder the ability to verify eligibility for assistance.
  • Recommended Follow-Up: Management should establish stronger internal controls to ensure all necessary documentation is collected and maintained for each tenant file.

Finding Text

2023-001 – Eligibility for Housing Assistance Significant Deficiency Criteria: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person’s family, including persons important to their care and well-being, as defined in 24 CFR 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 4 -- Missing documentation of landlord participation agreements, 1 -- Missing documentation of landlord participation agreements, due to incomplete record of transfer from WNCHS, 1 -- Missing documentation of lease contract, 2 – Missing documentation of housing assistance form. Cause: The shift to remote work and varying levels of technical knowledge among staff on digital record keeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten. In addition, WNCAP was in the process of implementing Electronic Health Records (Apricot) when the COVID crisis began. Effect: Compliance with eligibility could not be determined for some sampled tenants. Therefore, some ineligible individuals may have received assistance under the program. Questioned Costs: Undeterminable Context: During the year, 83 unique clients were served. We sampled 20 tenant files for multiple compliance requirements. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2022-002. Recommendation: Management should implement internal control procedures to ensure that all required documentation for determining eligibility is obtained and included in each tenant file. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.

Corrective Action Plan

2023-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 4 -- Missing documentation of landlord participation agreements, 1 -- Missing documentation of landlord participation agreements, due to incomplete record of transfer from WNCHS, 1 -- Missing documentation of lease contract, 2 -- Missing documentation of housing assistance form. Corrective Action: As outlined in previous year’s corrective action plan, WNCAP has implemented an eligibility checklist to ensure that client records are complete. The Housing Coordinator has shared the review checklist with frontline employees so they can use it as reference when completing intakes and recertifications, and she regularly reviews client files to ensure the records are complete. While the checklist was implemented in the first quarter of 2023, some of the records were created prior to implementation. Going forward, all records for the following audit period will have been created after implementation of the review checklist. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2021-22 audit: 2021-22 Total Deficient Eligibility Records: 30 2022-23 Total Deficient Eligibility Records: 8 WNCAP expects to see continued improvement in subsequent audits.

Categories

Eligibility Significant Deficiency

Other Findings in this Audit

  • 389349 2023-002
    Significant Deficiency Repeat
  • 965790 2023-001
    Significant Deficiency Repeat
  • 965791 2023-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.241 Housing Opportunities for Persons with Aids $723,567
93.917 Hiv Care Formula Grants $164,404
93.940 Hiv Prevention Activities_health Department Based $161,250
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $126,944
93.361 Nursing Research $45,610
93.488 National Harm Reduction Technical Assistance and Syringe Services Program (ssp) Monitoring and Evaluation Funding Opportunity $18,750