Finding 47976 (2022-002)

Material Weakness
Requirement
E
Questioned Costs
$1
Year
2022
Accepted
2023-06-29
Audit: 41921
Organization: Seattle Indian Health Board (WA)

AI Summary

  • Core Issue: Nine out of 28 payments lacked documentation proving household eligibility for the Eviction Rent Assistance Program.
  • Impacted Requirements: Eligibility criteria include income limits and proof of missed rent payments, which were not met for approximately $90,000 in payments.
  • Recommended Follow-Up: Implement stronger internal controls and ensure program managers understand compliance requirements to prevent future documentation issues.

Finding Text

Finding 2022-002 Eligibility Federal Agency: U.S. Department of the Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Program Assistance Listing Number: 21.027 Award Period: 9/1/2021 ? 6/30/2023 Type of Finding: Material Weakness in Internal Control over Compliance and Compliance Criteria or specific requirement: Eligibility requirements under contract 21-4619C-201 Eviction Rent Assistance Program 2.0 with the Washington State Department of Commerce require households to meet the criteria of income at or below 80% of Area Median Income and have missed or past due rent payment not paid or partially unpaid since March 1, 2020 and still be occupying the residence. Condition: Documentation that a household met the eligibility requirements of the program was unable to be located for 9 of the 28 payments selected for testing. Questioned Costs: Of the 10 households that were found to be unsupported by sufficient documentation of eligibility benefit payments totaling approximately $90,000 were processed. Extrapolation of the error rate calculated based upon the testing performed resulted in an estimated error of approximately $582,000 of potentially unsupported benefit payments in the remaining untested benefit payments. Context: The terms of the contract required documentation of household eligibility for benefits. Due to turnover of grant staff a number of records are unable to be located. Cause: Insufficient internal control processes and procedures to retain documentation that support determinations for eligibility of grant recipients to receive benefit under a federal award program. Effect: The Health Board awarded benefits to recipients that may not have been eligible under the contract requirements. Recommendation: The Health Board should ensure that program managers are aware of the significant compliance requirements of an award and implement a system of internal control that supports compliance and documentation of compliance.

Corrective Action Plan

U.S. DEPARTMENT OF TREASURY 2022-002 Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: The Health Board should ensure that program managers are aware of the significant compliance requirements of an award and implement a system of internal control that supports compliance and documentation of compliance. Explanation of disagreement with audit finding: We respectfully disagree with the characterization of the finding as a material weakness in internal control. The sample size of 28 selections called for 3 specific source documents to be provided in association with each sample. Thus, 10 out of a total of 84 source documents requested were not immediately available. The eligibility forms in question are part of the process which initiates the determination of the validity of the request for assistance. Due to the sensitive nature of this program, these documents are not readily available electronically (in order to protect the privacy of the recipients). The Health Board?s Community Services Team, which includes Rapid Rehousing, Gender-Based Violence, and Emergency Housing, experienced significant turnover due to the pandemic. We have informed the auditor about the turnover challenges faced by this specific department and the difficulties in securing physical documentation. Action taken in response to finding: In September 2022, the Community Service Team began reporting to the Health Board?s Behavioral Health Officer. Under her direction, processes have been updated and documented along with the creation of a stronger review process. The health board remains committed to further strengthening our controls and processes where necessary. We will ensure that program managers are aware of the compliance requirements associated with the award and implement a robust system of internal control that supports compliance and proper documentation. Name(s) of the contact person(s) responsible for corrective action: Linda Zhang, CFO Planned completion date for corrective action plan: September 30, 2023 If the U.S. Department of Treasury has questions regarding this plan, please call Linda Zhang, CFO at (206) 324-9360.

Categories

Questioned Costs Eligibility Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 624418 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.193 Covid-19 Urban Indian Health Services $6.13M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $2.04M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.53M
93.479 Good Health and Wellness in Indian Country (a) $1.52M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $1.43M
93.224 Covid-19 American Rescue Plan Act Funding for Health Centers $1.19M
93.762 A Comprehensive Approach to Good Health and Wellness in Indian County ? Financed Solely by Prevention and Public Health $959,847
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $718,799
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $595,038
93.231 Epidemiology Cooperative Agreements $558,760
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $352,750
93.237 Special Diabetes Program for Indians_diabetes Prevention and Treatment Projects $327,425
93.193 Urban Indian Health Services $317,646
93.231 Covid-19 - Epidemiology Cooperative Agreements $276,370
93.498 Provider Relief Fund $257,745
93.788 Opioid Str $41,077
16.023 Sexual Assault Services Cuturally Specific Program $38,915
21.019 Coronavirus Relief Fund $21,190
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $13,530
47.076 Education and Human Resources $12,309
93.380 The Cdc Public Health Cancer Genomics Program: Translating Research Into Public Health Practice (b) $1,833
93.958 Block Grants for Community Mental Health Services $520
21.023 Emergency Rental Assistance Program $151