FAC Explorer

Finding 39683 (2022-003)

Significant Deficiency
Requirement
E
Questioned Costs
$1
Year
2022
Accepted
2023-07-10
Audit: 37825
Organization: Cook County, Illinios (IL)
Auditor: Washington Pittman & McKeever LLC

AI Summary

  • Core Issue: The Cook County Department of Planning and Development did not follow federal eligibility rules for rental assistance, leading to overpayments.
  • Impacted Requirements: Households should not receive more than 18 months of assistance combined from ERA 1 and ERA 2, and payments must be made only during eligible periods.
  • Recommended Follow-up: DPD should create and enforce procedures to ensure compliance with federal regulations and prevent future overpayments.

Finding Text

Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 CRITERIA Per the U.S Department of the Treasury, Emergency Rental Assistance, Frequently Asked Questions, revised July 27, 2022 (FAQ), ?In ERA 1, an eligible household may receive up to twelve (12) months of assistance (plus an additional three (3) months if necessary to ensure housing stability for the household, subject to the availability of funds). The aggregate amount of financial assistance an eligible household may receive under ERA 2, when combined with financial assistance under ERA 1, must not exceed 18 months.? In addition, the FAQ states, ?In ERA1, financial assistance for prospective rent payments is limited to three months based on any application by or on behalf of the household, except that the household may receive assistance for prospective rent payments for additional months (i) subject to the availability of remaining funds currently allocated to the grantee, and (ii) based on a subsequent application for additional assistance. In no case may an eligible household receive more than 18 months of assistance under ERA 1 and ERA 2, combined.? CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not adequately comply with federal regulations over eligibility requirements. CAUSE Based on discussions with management, this finding occurred due to an oversight in the procedure to check payments for the monthly cap of eighteen months by a reviewer, as the system did not have a calculated field on ?number of months? paid with a built-in cap that was subsequently added to the application system to limit payments to the cap number of months (18) for ERA I, ERA II combined. EFFECT The failure to ensure rental assistance payments are made during the periods allowed under the program is a violation of federal regulations. This could result in ineligible participants being paid/charged to the federally funded program. QUESTIONED COSTS We noted total potential questioned costs in the amount of $12,712. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 (Continued) CONTEXT During our test of 40 participants, we noted a total of 5 participants received ERA 1 and/or ERA 2 rental assistance payments either beyond the maximum period allowed or during ineligible periods. Specifically, we noted the following: *Two participants received ERA 1 payments beyond the 15 months allowed. *One participant received both ERA 1 and ERA 2 payments beyond the 18 months allowed. *One participant was overpaid 3 months of future rental assistance payment. *One participant received rental assistance payment before March 13, 2020, the date of the emergency declaration pursuant to section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5191(b), which were during ineligible periods. These issues resulted in the overpayment of rental assistance during fiscal year 2022 totaling $12,712. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DPD develop and implement procedures to ensure compliance with federal regulations. Also, procedures should be in place to ensure rental assistance payments does not exceed the maximum period allowed under the program and is within the periods allowed. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 61.

Corrective Action Plan

Findings 2022 ? 003 Emergency Rental Assistance (ERA) Program Federal Assistance Listing # (21.023) ? Allowable Costs/Eligibility Corrective Action Plan: Key considerations are: Treasury added flexibility between the ERA 1 and 2 programs relaxed the burden of proof necessary for applicants to qualify for funding. 1. The reduction of burden and qualifications allowed for self-attestation, third party income verification or certification, and internal policies to reduce burden as supported by the Treasury. 2. Rental payments calculations and assumptions on timing may not have taken into consideration the FAQ guidance covering overall ceilings on payments in ERA I funding once ERA II was in place, which allowed for an 18-month cap on both funding sources. DPD will continue to work towards recovering over-allocations to awardees and initiate collection efforts directed towards owners and landlords. As we finalize the ERA II program by September 2024, DPD will reconcile the payment status of the ERA II awardees and notify awardees of overpayment and repayment requirements. Please reference the following: ERA-FAQ and ERA Questions. https:www.google.com/url?sa=t&source=web&rct=j&url=https:home.treasury.gov/system/files/136/ERA-FAQ-8-25-2021.pdf&ved=2ahUKEwjZ05HLjOL_AhVEkmoFHaXiAMwQFnoECCIQAQ&usg=AOvVaw1SKQl-IN3zig70bkVCxj9C

Categories

Questioned Costs Eligibility

Other Findings in this Audit

  • 39681 2022-001
    Significant Deficiency
  • 39682 2022-002
    Significant Deficiency
  • 39684 2022-003
    Significant Deficiency
  • 39685 2022-007
    Significant Deficiency
  • 39686 2022-008
    Significant Deficiency
  • 39687 2022-009
    Significant Deficiency
  • 39688 2022-010
    Significant Deficiency Repeat
  • 39689 2022-005
    Significant Deficiency
  • 39690 2022-006
    Significant Deficiency Repeat
  • 39691 2022-004
    Significant Deficiency
  • 616123 2022-001
    Significant Deficiency
  • 616124 2022-002
    Significant Deficiency
  • 616125 2022-003
    Significant Deficiency
  • 616126 2022-003
    Significant Deficiency
  • 616127 2022-007
    Significant Deficiency
  • 616128 2022-008
    Significant Deficiency
  • 616129 2022-009
    Significant Deficiency
  • 616130 2022-010
    Significant Deficiency Repeat
  • 616131 2022-005
    Significant Deficiency
  • 616132 2022-006
    Significant Deficiency Repeat
  • 616133 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $166.10M
93.498 Provider Relief Fund $31.16M
97.067 Homeland Security Grant Program $19.96M
95.001 High Intensity Drug Trafficking Areas Program $17.79M
14.218 Community Development Block Grants/entitlement Grants $13.52M
93.563 Child Support Enforcement $8.36M
20.205 Highway Planning and Construction $8.11M
14.239 Home Investment Partnerships Program $6.01M
93.268 Immunization Cooperative Agreements $5.31M
14.231 Emergency Solutions Grant Program $5.13M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $4.55M
21.023 Emergency Rental Assistance Program $2.50M
14.269 Hurricane Sandy Community Development Block Grant Disaster Recovery Grants (cdbg-Dr) $2.07M
16.575 Crime Victim Assistance $1.57M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $1.42M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $1.35M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $931,606
93.069 Public Health Emergency Preparedness $887,672
93.788 Opioid Str $831,960
93.959 Block Grants for Prevention and Treatment of Substance Abuse $792,572
93.136 Injury Prevention and Control Research and State and Community Based Programs $752,205
16.738 Edward Byrne Memorial Justice Assistance Grant Program $696,342
66.001 Air Pollution Control Program Support $686,074
16.543 Missing Children's Assistance $657,103
93.926 Healthy Start Initiative $642,438
16.588 Violence Against Women Formula Grants $548,463
97.042 Emergency Management Performance Grants $546,515
93.495 Community Health Workers for Public Health Response and Resilient $524,460
21.016 Equitable Sharing $522,217
21.027 Coronavirus State and Local Fiscal Recovery Funds $495,607
93.884 Grants for Primary Care Training and Enhancement $429,240
10.555 National School Lunch Program $367,132
16.034 Coronavirus Emergency Supplemental Funding Program $366,158
16.827 Justice Reinvestment Initiative $332,345
90.404 2018 Hava Election Security Grants $305,823
93.247 Advanced Nursing Education Grant Program $305,068
14.905 Lead Hazard Reduction Demonstration Grant Program $303,865
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $301,984
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $271,707
16.585 Drug Court Discretionary Grant Program $270,194
16.922 Equitable Sharing Program $257,715
16.320 Services for Trafficking Victims $248,536
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $212,094
16.582 Crime Victim Assistance/discretionary Grants $208,836
16.838 Comprehensive Opioid Abuse Site-Based Program $193,851
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $182,908
10.553 School Breakfast Program $170,457
16.825 Smart Prosecution Initiative $170,290
20.530 Public Transportation Innovation $164,297
93.226 Research on Healthcare Costs, Quality and Outcomes $143,304
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $141,026
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $134,043
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $128,386
93.586 State Court Improvement Program $121,220
16.752 Economic High-Tech and Cyber Crime Prevention $111,583
16.836 Indigent Defense $108,212
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $103,931
16.593 Residential Substance Abuse Treatment for State Prisoners $87,018
16.540 Juvenile Justice and Delinquency Prevention_allocation to States $86,632
20.600 State and Community Highway Safety $75,060
12.617 Economic Adjustment Assistance for State Governments $63,905
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $61,381
93.855 Allergy, Immunology and Transplantation Research $57,033
93.217 Family Planning_services $56,907
93.669 Child Abuse and Neglect State Grants $55,296
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $55,000
16.021 Justice Systems Response to Families $53,487
93.253 Poison Center Support and Enhancement Grant $40,520
93.439 State Physical Activity and Nutrition (span $34,000
11.307 Economic Adjustment Assistance $33,508
16.754 Harold Rogers Prescription Drug Monitoring Program $32,962
17.285 Apprenticeship USA Grants $26,312
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $20,000
66.032 State Indoor Radon Grants $5,007
66.605 Performance Partnership Grants $1,388
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $477
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $100
93.110 Maternal and Child Health Federal Consolidated Programs $-455
16.812 Second Chance Act Reentry Initiative $-25,834
21.019 Coronavirus Relief Fund $-87,542
93.667 Social Services Block Grant $-248,432