Finding 499239 (2023-004)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-09-28
Audit: 322033
Organization: Home Forward (OR)

AI Summary

  • Core Issue: Home Forward lacks adequate internal controls for documenting the approval of comparables in rental files.
  • Impacted Requirements: This affects compliance with §200.303, which mandates effective internal controls over federal awards.
  • Recommended Follow-Up: Implement controls to ensure formal documentation of comparables is consistently maintained in all relevant files.

Finding Text

Criteria or specific requirement: According to §200.303 Internal controls of 2 CFR Part 200, the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Authority is required to establish a reasonable rent policy and ensure that policy is followed. Condition: During our testing, we noted Home Forward did not have adequate internal controls designed to ensure the approval of comparables is formally documented in the files. Questioned costs: Unable to determine. Context: During our testing, it was noted that Home Forward did not formally document approval of comparables in 4 of 40 files. Cause: Home Forward has not been consistent with keeping formal documentation of approval of comparables in the files. Effect: The auditor noted no instances of noncompliance with the provisions of special tests and provisions - reasonable rental rates; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No. Recommendation: We recommend Home Forward design controls to ensure formal documentation of approval of comparables is in the files. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend Home Forward design controls to ensure formal documentation of approval of comparables is in the files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Home Forward will add clarifying language in our Shelter Plus Care (Continuum of Care) Program operating manual indicating need for staff to document who completed rent reasonableness reviews including signatures from program supervisors or department staff responsible for approving comparables when necessary as part of the rent reasonableness review. Additional staff training will be conducted during Shelter Plus Care and department team meetings. Name(s) of the contact person(s) responsible for corrective action: Ian Slingerland, Director of Homeless Initiatives and Supportive Housing Planned completion date for corrective action plan: 10/1/2024

Categories

Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 499236 2023-001
    Significant Deficiency
  • 499237 2023-002
    Significant Deficiency
  • 499238 2023-003
    Significant Deficiency
  • 1075678 2023-001
    Significant Deficiency
  • 1075679 2023-002
    Significant Deficiency
  • 1075680 2023-003
    Significant Deficiency
  • 1075681 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $133.36M
14.871 Section 8 Housing Choice Vouchers $46.98M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $9.87M
14.874 Emergency Housing Vouchers $8.21M
14.267 Continuum of Care Program $7.79M
14.879 Section 8 Mainstream Vouchers $2.70M
14.896 Family Self-Sufficiency Program $797,904
21.023 Covid-19 Emergency Rental Assistance Program $687,429
14.191 Multifamily Housing Service Coordinators $456,407
97.024 Emergency Food and Shelter National Board Program $449,460
14.856 Lower Income Housing Assistance Program Section 8 Moderate Rehabilitation $281,667
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $189,497
14.218 Covid-19 Cdbg-Cv $115,686
32.011 Affordable Connectivity Outreach Grant Program $42,386
14.866 Demolition and Revitalization of Severely Distressed Public Housing $37,235