Finding 41769 (2022-006)

Federal Awards Finding 2022-006 - Emergency Rental Assistance Eligibility Corrective Action Plan: Please see responses to 2022-002, 2022-004, and 2022-005. Responsible Official: Devon Manning, Director of Policy & Planning and Brian Rossello, Director of Housing Finance Completion Date: August 2021 Financial Statement Finding 2022-002 - Internal Control Over Compliance - United States Emergency Rental Assistance Program Corrective Action Plan: DSHA has implemented a Corrective Action Plan which it believes fully addresses the internal control weaknesses identified in connection with the audit finding of a material weakness related to DSHA?s operation of the Emergency Rental Assistance (?ERA?) program. The Corrective Action Plan is comprised of three key elements: 1. Implementation of a new software system that fully addresses certain process issues encountered with its existing software application. 2. Implementation of new process workflows and approvals performed by DSHA personnel to ensure proper approval of case applications and payment of approved applications to proper vendors. 3. Engaging an external consultant to analyze, verify and remediate, as required, applications processed in the predecessor software system. Each of these three elements is further discussed below. In August 2021, DSHA implemented a new software application to accept and process applications for the ERA program and replace its existing application. DSHA implemented this system as a means to correct and resolve the issues it was experiencing with respect to timely and accurate payment processing. The new system included significant improvements in workflow related to payment processing and account verification, as well as other needed program features. With the new software application, one of the root causes of DSHA?s application payment issues was immediately addressed, by eliminating the need to manually upload vendor payment information from its predecessor application to DSHA?s accounting system for payment. The prior manual upload process resulted in various vendor payment issues and erroneous payments. The new software application is a completely self-contained application, with workflow approvals that span from application submittal and approval to vendor payment. Each week all approved applications are automatically batched and sent to DSHA for approval prior to payment. This workflow has resolved previous issues where payments were not made timely for approved applications. The new software application incorporates significant improvements to payment processing and account verification. As mentioned above, there is no need to transfer or upload data between new software application and the accounting system to effect payments of approved applications. The new software application includes a verification process whereby the vendor ACH information is verified by a ?penny test? or small deposit that the user must verify. ACH payments can only be made to accounts that are verified. Once payments are made through new software application, batch details are imported to the accounting software via a custom interface for accounting system transaction reporting. Implementation of New Process Workflows, Approvals and Verifications by DSHA Coupled with the new software application implementation, DSHA implemented updated ERA Program Guidelines and new internal policy and process manuals to ensure its internal controls and processes appropriately addressed the compliance requirements of the ERA program and to ensure properly approved applications are paid to proper vendors. All cases in Approved Status are batched each week by the new software application and sent to DSHA for approval. DSHA reviews each of the approved applications within the batch and approves the batch once verified. At that point, requested funds are wired and payments issued by the new software application. This process has resolved previous instances of non-payment of approved cases. DSHA has developed new Case Auditor and Case Supervisor Process Guides and Checklists, which now standardize the processes used to review, verify and approve applications prior to payment. The new software application case management workflow requires separate Case Auditor and Case Supervisor verification of program requirements and payments prior to approval and payment of an application. Remediation of Prior Case Applications Processed in the predecessor application DSHA has engaged a third-party external consultant to assist it in ensuring that the applications processed in the predecessor application system resulted in payments to appropriate vendors for proper, compliant applications. The objective of this assessment is to identify any applications processed within predecessor application that resulted in either over or under payment to the vendor recipient. Once identified, these over and/or under payments will be remediated. These action plans have been implemented beginning August 2021 for the 2022 Fiscal Year and will remain in effect going forward. Responsible Official: Marlena Gibson, Director of Policy and Planning. Responsible Official: Marlena Gibson, Director of Policy and Planning. Financial Statement Finding 2022-004 ? Internal Control Over Compliance ? United States Emergency Rental Assistance Program Corrective Action Plan: DSHA will take these recommendations under advisement, and review program policies and procedures to ensure they are in accordance with statutory requirements. DSHA will ensure that staff responsible for processing DEHAP applications are training effectively in how to interpret and apply program policies and procedures, and will clearly communicate the expectation that review staff adhere to program policies and procedures consistently. DSHA would like to request clarification on Belfint's interpretation of the statutory requirement around security deposits. To our knowledge, UST has suggested applying a limit of one month's rent as guidance, but has not made this an actual requirement of the federal Emergency Rental Assistance Program. Responsible Official: Marlena Gibson, Director of Policy and Planning.