Finding Text
Finding 2023-003: Level of Effort—Significant Deficiency
U.S. Department of Housing and Urban Development
Passed through the Missouri Department of Mental Health
Continuum of Care Program, Federal Assistance Listing No. 14.267
Federal award year 2023
Criteria: The OMB Compliance Supplement and terms of the grant agreements include level of effort requirements, where the recipient is required to use grant funds to supplement and not supplant other funds, when providing assistance to home persons or persons at-risk of homelessness.
Condition: The Organization did not consistently provide documentation providing evidence of the individual’s qualifications for receiving rent and/or utility assistance. Supporting documentation for some individuals selected for testing, only included evidence of payment made to the landlord and/or utility company, but documentation was not consistently available that supported the tenant’s eligibility to receive these assistance payments. In addition, the Organization did not consistently retain documentation providing evidence of review and approval by the Organization’s staff prior to payment or drawdowns. Supporting documentation for some individuals selected for testing, included evidence of a rental agreement in existence between the tenant and landlord, but documentation was not consistently retained that supported the Organization’s review and approval of these tenant support payments.
Cause: A lack of available documentation, as well as documentation with evidence of review. For 3 of the selections with unavailable documentation, the Organization is no longer providing assistance to these tenants/patients.
Effect or potential effect: The potential effect is that the Organization is not in compliance with grant requirements.
Questioned costs: None.
Context: For 3 of 50 selections made, supporting documentation was provided of the payment made to a utility company or landlord for on behalf of a tenant; however, not all documentation was made available that provided evidence of the tenant’s qualification for receiving these funds. In addition, management discussed reports that are reviewed when processing payments for tenants, but documentation providing evidence of these reviews and approvals was not consistently available for each selection for reperformance.
Identification as a repeat finding, if applicable: This is not a repeat finding.
Recommendation: We recommend the Organization implement procedures to ensure all relevant documentation is retained to support the payments made with the grant funds.
Views of responsible officials and auditee: Management agrees with this finding. See corrective action plan.