Finding 40064 (2022-003)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2022
Accepted
2023-04-27
Audit: 45011
Organization: Legal Services Alabama, INC (AL)

AI Summary

  • Core Issue: There are discrepancies in client assistance payments and payroll allocations, leading to non-compliance with documentation requirements.
  • Impacted Requirements: Compliance with 2 CFR 200.403, which mandates that costs must be adequately documented and accurately calculated.
  • Recommended Follow-up: Strengthen policies and procedures for calculating assistance payments to ensure accuracy and compliance with documentation standards.

Finding Text

Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.

Corrective Action Plan

Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Corrective Action: The ARPA?s stated purpose is for housing provision, stabilization services, and eviction prevention. The rental assistance funds may be used for arrearage, forward payments, deposits, late fees, and utilities. The grant provides separate application forms for rental assistance and utilities assistance. The grant does not require maximizing the amount paid on behalf of applicants. Every disbursement involves obtaining documents from the applicant and the landlord. The landlord signs an agreement stating they will allow the client to remain housed by accepting the payment. It is common to negotiate the agreed upon amount because some landlords include fees in their amounts that are not allowable under the grant or ask for more months of assistance that is allowed. The disbursements tested included agreements that were all signed and accepted by the landlords. LSA documented the costs which were reimbursed by the funder. One of the payments included a document that had not been updated. The payment included an additional month?s rent due to the time lag between the start of the application and the completed documents and the revised total amount was included on the signed landlord agreement. In this case, the agreement did not include an additional late fee that would have been expected per the terms of the lease. The landlord accepted the payment less the late fee. LSA staff will document negotiated amounts that are different from the support and provide explanation and the amount included or excluded. A second payment did not include a beginning ledger balance. The landlord charges an insurance fee that is not covered by the grant. Rather than attempting to determine if the balance forward was due to eligible charges or ineligible charges, the amount was excluded from the total. The documentation attached did not specifically mention that the amount was excluded, but a handwritten total of the included charges was included. LSA staff will document negotiated amounts that are different from the support and provide explanation and the amount included or excluded. The third payment was deemed an exception because the reimbursement did not include the client?s utilities charges. Although the charges are eligible under the grant, the applicant and landlord did not request assistance with utilities. LSA staff will document negotiated amounts that are different from the support and provide explanation and the amount included or excluded. Regarding employee time for the program, LSA staff will look for solutions to help prevent time entry errors, and the Finance Department will conduct a review of every grant report. LSA will review if changes can be made in the timekeeping system to restrict certain fund sources from being applied to programs, to enhance controls over time attributed to particular funding. The grant report review will also include a review of program reports when new staff join the program to ensure the time activity is correct and can be allocated as reported. LSA will complete a review of the timekeeping system and procedures by the end of the second quarter 2023 and implement changes by the third quarter of 2023. The grant report review will commence as of the date of this audit report. Contact Person: David Roberson, Director of Finance; (334) 223-0251; droberson@alsp.org

Categories

Allowable Costs / Cost Principles Cash Management Significant Deficiency

Other Findings in this Audit

  • 40060 2022-002
    Significant Deficiency Repeat
  • 40061 2022-002
    Significant Deficiency Repeat
  • 40062 2022-002
    Significant Deficiency Repeat
  • 40063 2022-002
    Significant Deficiency Repeat
  • 40065 2022-004
    Significant Deficiency
  • 40066 2022-005
    Significant Deficiency
  • 40067 2022-003
    Significant Deficiency
  • 40068 2022-004
    Significant Deficiency
  • 40069 2022-005
    Significant Deficiency
  • 40070 2022-003
    Significant Deficiency
  • 40071 2022-004
    Significant Deficiency
  • 40072 2022-005
    Significant Deficiency
  • 40073 2022-003
    Significant Deficiency
  • 40074 2022-004
    Significant Deficiency
  • 40075 2022-005
    Significant Deficiency
  • 40076 2022-003
    Significant Deficiency
  • 40077 2022-003
    Significant Deficiency
  • 616502 2022-002
    Significant Deficiency Repeat
  • 616503 2022-002
    Significant Deficiency Repeat
  • 616504 2022-002
    Significant Deficiency Repeat
  • 616505 2022-002
    Significant Deficiency Repeat
  • 616506 2022-003
    Significant Deficiency
  • 616507 2022-004
    Significant Deficiency
  • 616508 2022-005
    Significant Deficiency
  • 616509 2022-003
    Significant Deficiency
  • 616510 2022-004
    Significant Deficiency
  • 616511 2022-005
    Significant Deficiency
  • 616512 2022-003
    Significant Deficiency
  • 616513 2022-004
    Significant Deficiency
  • 616514 2022-005
    Significant Deficiency
  • 616515 2022-003
    Significant Deficiency
  • 616516 2022-004
    Significant Deficiency
  • 616517 2022-005
    Significant Deficiency
  • 616518 2022-003
    Significant Deficiency
  • 616519 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
09.U01 Legal Services Corporation Basic Field Grant $7.38M
14.231 Emergency Solutions Grant Program $665,923
93.747 Elder Abuse Prevention Interventions Program $268,973
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $246,218
21.023 Emergency Rental Assistance Program $180,029
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $126,244
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $125,053
21.008 Low Income Taxpayer Clinics $100,000
16.575 Crime Victim Assistance $88,844
09.U02 Lsc Disaster Project Grant $75,144
16.589 Rural Domestic Violence, Dating Violence, Sexual Assault, and Stalking Assistance Program $31,169
09.U03 Lsc Disaster Grant Incurred Cost $25,216
14.169 Housing Counseling Assistance Program $22,104
21.027 Coronavirus State and Local Fiscal Recovery Funds $7,478
21.026 Homeowner Assistance Fund $6,425
09.U04 Technology Innovation Grant $4,275
14.218 Community Development Block Grants/entitlement Grants $141
64.033 Va Supportive Services for Veteran Families Program $100