Finding Text
Compliance and Significant Deficiency in Internal Control over compliance with Special
Tests and Provisions
U.S. Department of Housing and Urban Development
Direct Program
Program Name: Continuum of Care
AL#: 14.267
Condition: For 2022, the Organization used rent calculation worksheets which had not been updated for the published utility rates for the area, or calculated based on HUD’s Utility Allowance Handbook.
Criteria: Per 24 CFR Section 578.77, the share of rent allowed to be charged to the tenant takes into consideration household income, size of the family and a credit for utilities included in the lease.
Context: 20 cases from a total population of 40 were selected for testing. The utility rates were out of date on all files tested.
Cause: The Organization did not update their records and calculation worksheets for the change in the published utility rates or self- calculate the rates based on the Utility Allowance Handbook.
Effect: The Organization is not in compliance with the requirements of the Continuum of Care program with respect to Special Test Requirements for Reasonable Rental Rates. The calculation of the correct tenant’s portion impacts the balance paid by the Organization and subsequently charged to the HUD grants.
Recommendation: We recommend that written procedures addressing internal controls with respect to tracking changes in program requirements be implemented and that procedures to update any worksheets for the effect of those requirements be performed and verified to ensure that the Organization is in compliance at all times.
View of Responsible
Officials: Mental Health Association in Orange County Inc.’s (MHA) management concurs with this finding. The Organization is in the process of implementing procedures to ensure that compliance is maintained in the future. Please refer to the corrective action plan on pages 13 - 14.