Finding 392629 (2022-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2024-04-09
Audit: 302930
Organization: Impact Community Action (OH)

AI Summary

  • Core Issue: Incomplete eligibility documentation was found in 5 out of 25 samples during testing for the Emergency Rental Assistance Program.
  • Impacted Requirements: Compliance with eligibility criteria as outlined in Section 200.303 of the Uniform Guidance is not being met, risking improper disbursements.
  • Recommended Follow-Up: Program specialists must ensure all required documentation is completed and retained for each applicant, following the eligibility checklist provided by IMPACT.

Finding Text

2022-001 Supporting Documents for Eligibility Requirements Program Name/ Assisting Listing Title: Emergency Rental Assistance Program Federal Assistance Listing No.: 21.023 Federal Agency: Department of Treasury Federal Award Identification: Unknown Pass-Through Entity Number: 0323-22, 0423-22, 0668-22, 25-21-3556 Applicable Pass-Through Entity: Franklin County Department of Job and Family Services Type of Finding: Significant Deficiency Compliance Requirement: Eligibility Criteria: According to Section 200.303 of the Uniform Guidance, a non_x0002_federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. IMPACT must document their policies and procedures in determining eligibility and must have controls in place to ensure compliance with their policies and procedures and prevent fraud. Condition: During the 21.023 eligibility testing, five out of twenty-five samples have incomplete eligibility documentation. Four of these five exceptions did not have duplicative form, and documentation of eligible cost. Of these four, one did not have documentation of hardship. One exception did not have an intake form. Upon further review, applicants were eligible. Cause of Condition: Program specialist failed to obtain or retain the complete eligibility documentation. Effect: Incomplete eligibility documentation creates a challenge in promptly verifying eligibility, thereby posing a risk of improper disbursements to individuals who do not meet the eligibility criteria. Questioned Cost: $0 Recommendation: Program specialists should verify all documentation is completed and retained for each applicant as prescribed by IMPACTS eligibility checklist. Context: 21.023 – Of the 46,088 payment vouchers, we examined 25 samples wherein we noted 5 exceptions.

Corrective Action Plan

Contact Person: Shameikia Smith, VP of Housing Services We agree with the finding. Clear documentation of eligibility requirements for each grant should be communicated with program personnel and should be verified for each applicant. In May of 2023, we implemented an internal auditing system to ensure compliance with grant/funding requirements, ensuring eligibility and eligible costs. 50 files are reviewed each month. Any deficiencies are required to be updated within two-weeks of the receipt of the report. As of 2024, there is stability in the staffing pattern and leadership of the Emergency Rental Assistance Program. In February of 2024, the Emergency Rental Assistance team is now combined with our Housing Services department. This change will help mitigate risk and increase compliance to 100%. Completion Date: Completion Date February 29, 2024

Categories

Subrecipient Monitoring Eligibility Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 969071 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.023 Emergency Rental Assistance Program $74.85M
93.568 Low-Income Home Energy Assistance $5.45M
93.569 Community Services Block Grant $4.01M
14.218 Community Development Block Grants/entitlement Grants $1.17M
93.558 Temporary Assistance for Needy Families $823,424
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $813,233
81.042 Weatherization Assistance for Low-Income Persons $699,022
17.259 Wia Youth Activities $618,782
21.026 Homeowner Assistance Fund $426,291
21.027 Coronavirus State and Local Fiscal Recovery Funds $120,555
21.019 Coronavirus Relief Fund $52,896