Finding 3917 (2023-002)

Continuum of Care, Assistance Listing Number 14.267 Criteria: Special Tests and Provisions Reasonable Rental Rates. 24 CFR 578.49(b)(1) of the Continuum of Care Program requires rents paid for with grant funds to be reasonable and to not exceed fair market rents. The Agency should have internal controls in place to ensure compliance. Condition: We noted an instance (out of a sample of 19) of a client’s original lease ending and no documentation being retained to indicate the future status of the lease in accordance with the Agency’s policies and controls. Cause and Effect: The Agency may pay rent for a lease that is not housing a client or is in excess of fair market rents for a similar unit. The Agency did not adhere to its internal controls of obtaining a lease addendum or new lease at the conclusion of a previous lease. Recommendation: The Agency should provide education and training for all staff members involved in the program. In addition, management needs to perform a review of all client files to ensure proper documentation is retained for all clients and ongoing leases. Views of Responsible Officials and Planned Corrective Actions: Recommendation will be implemented including education and training of staff members responsible for lease documents. Agency will also complete a review of all client files to ensure properly inclusion of appropriate documentation. See corrective action plan on page 32.