Finding 499414 (2023-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-09-30

AI Summary

  • Core Issue: One program provider failed to provide adequate documentation for rent reasonableness, with incomplete records for multiple rental units.
  • Impacted Requirements: Compliance with federal grant terms regarding reasonable rent determination was not met, as proper documentation was lacking.
  • Recommended Follow-Up: DHS should ensure annual monitoring of rent reasonableness and require documentation from all program providers.

Finding Text

Condition: When we requested DHS to obtain documentation supporting rent reasonableness for 2023 from three randomly selected program providers, we observed that the documentation supplied by one of the three providers was not sufficient to demonstrate that rent reasonableness was determined. For one of the Continuum of Care (CoC) projects administered by this provider, documentation was only supplied for 21 of 40 rental units, and the documentation had 2024 dates that approximated the date of our request for the information. For the other CoC project administered by this same provider, documentation was only supplied for 5 of 25 rental units, and the documentation had 2021 or earlier dates. This is a repeat finding from 2022. Criteria: When program funds are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable units. Cause: DHS developed and implemented its own rent reasonableness policy and provided a rent reasonableness policy template to the CoC program providers to facilitate their development and implementation of such policies. However, DHS did not take adequate measures to ensure that all CoC program providers had in fact implemented and were adhering to appropriate rent reasonableness policies. Effect: The County was not in compliance with the terms of the federal grant program. Questioned Costs: none Recommendation: The County Department of Human Services should take steps to ensure that DHS monitoring of rent reasonableness routinely occurs on an annual basis. In addition, DHS should document the determination of rent reasonableness for each program provider. Management Response: Management agrees with the finding, see attached Corrective Action Plan.

Corrective Action Plan

Programs were instructed to update all current client files to include the rent reasonableness studies and this should happen annually when the lease is renewed or any time a client needs to move to another unit. Providers are also now maintaining a rent reasonableness tracking sheet with all rent related information for units considered for the rent reasonableness analysis. Also, during each monthly invoice review, program staff look at each rent payment within each grant and flag any rents that seem excessive and reach out to the provider with any questions. If the rent is deemed too high or ineligible we will ask the provider to remove the amount from the invoice. We also have an updated, HUD approved, Rent Reasonableness policy, which has been provided to all housing providers.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 499415 2023-002
    Material Weakness
  • 499416 2023-003
    Material Weakness
  • 499417 2023-003
    Material Weakness
  • 499418 2023-003
    Material Weakness
  • 499419 2023-004
    Material Weakness Repeat
  • 499420 2023-005
    Material Weakness Repeat
  • 499421 2023-006
    Material Weakness
  • 499422 2023-007
    Material Weakness
  • 499423 2023-008
    Material Weakness
  • 499424 2023-008
    Material Weakness
  • 499425 2023-009
    Material Weakness
  • 499426 2023-009
    Material Weakness
  • 499427 2023-010
    Material Weakness
  • 499428 2023-010
    Material Weakness
  • 499429 2023-011
    Material Weakness
  • 499430 2023-012
    Material Weakness
  • 499431 2023-013
    Material Weakness
  • 499432 2023-013
    Material Weakness
  • 499433 2023-013
    Material Weakness
  • 1075856 2023-001
    Material Weakness Repeat
  • 1075857 2023-002
    Material Weakness
  • 1075858 2023-003
    Material Weakness
  • 1075859 2023-003
    Material Weakness
  • 1075860 2023-003
    Material Weakness
  • 1075861 2023-004
    Material Weakness Repeat
  • 1075862 2023-005
    Material Weakness Repeat
  • 1075863 2023-006
    Material Weakness
  • 1075864 2023-007
    Material Weakness
  • 1075865 2023-008
    Material Weakness
  • 1075866 2023-008
    Material Weakness
  • 1075867 2023-009
    Material Weakness
  • 1075868 2023-009
    Material Weakness
  • 1075869 2023-010
    Material Weakness
  • 1075870 2023-010
    Material Weakness
  • 1075871 2023-011
    Material Weakness
  • 1075872 2023-012
    Material Weakness
  • 1075873 2023-013
    Material Weakness
  • 1075874 2023-013
    Material Weakness
  • 1075875 2023-013
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.575 Child Care and Development Block Grant $41.92M
14.267 Continuum of Care Program $23.23M
20.205 Highway Planning and Construction $21.65M
93.658 Foster Care Title IV-E $18.86M
93.563 Child Support Services $16.73M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $16.38M
93.659 Adoption Assistance $13.89M
93.600 Head Start $13.71M
93.558 Temporary Assistance for Needy Families $13.03M
14.218 Community Development Block Grants/entitlement Grants $11.35M
21.023 Emergency Rental Assistance Program $8.35M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $7.26M
93.667 Social Services Block Grant $4.69M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $4.00M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $3.90M
93.090 Guardianship Assistance $3.41M
93.495 Community Health Workers for Public Health Response and Resilient $3.26M
93.958 Block Grants for Community Mental Health Services $2.91M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $2.56M
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $2.32M
97.067 Homeland Security Grant Program $1.87M
14.239 Home Investment Partnerships Program $1.83M
93.268 Immunization Cooperative Agreements $1.52M
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $1.33M
10.569 Emergency Food Assistance Program (food Commodities) $1.33M
84.181 Special Education-Grants for Infants and Families $1.16M
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $1.10M
93.645 Stephanie Tubbs Jones Child Welfare Services Program $1.08M
14.905 Lead Hazard Reduction Demonstration Grant Program $1.05M
94.006 Americorps State and National 94.006 $1.01M
93.052 National Family Caregiver Support, Title Iii, Part E $963,212
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $907,010
93.994 Maternal and Child Health Services Block Grant to the States $879,306
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $859,689
21.027 Coronavirus State and Local Fiscal Recovery Funds $771,528
93.069 Public Health Emergency Preparedness $732,517
93.053 Nutrition Services Incentive Program $633,980
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $568,712
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $551,526
16.922 Equitable Sharing Program $531,862
66.001 Air Pollution Control Program Support $500,000
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $491,764
14.889 Choice Neighborhoods Implementation Grants $484,232
93.788 Opioid Str $429,304
93.150 Projects for Assistance in Transition From Homelessness (path) $416,097
93.556 Marylee Allen Promoting Safe and Stable Families Program $412,929
93.940 Hiv Prevention Activities Health Department Based $366,336
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $349,153
16.738 Edward Byrne Memorial Justice Assistance Grant Program $347,073
93.136 Injury Prevention and Control Research and State and Community Based Programs $326,580
16.741 Dna Backlog Reduction Program $296,619
97.042 Emergency Management Performance Grants $295,267
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $281,330
16.833 National Sexual Assault Kit Initiative $270,542
17.259 Wioa Youth Activities $268,008
93.778 Medical Assistance Program $251,385
14.231 Emergency Solutions Grant Program $251,000
93.991 Preventive Health and Health Services Block Grant $213,294
20.600 State and Community Highway Safety $212,764
93.070 Environmental Public Health and Emergency Response $193,425
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $172,163
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation�s Health $164,536
16.528 Enhanced Training and Services to End Violence and Abuse of Women Later in Life $151,782
93.071 Medicare Enrollment Assistance Program $151,664
16.123 Community-Based Violence Prevention Program $143,095
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $141,576
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $133,505
16.588 Violence Against Women Formula Grants $131,354
95.001 High Intensity Drug Trafficking Areas Program $122,946
10.568 Emergency Food Assistance Program (administrative Costs) $118,456
21.032 Local Assistance and Tribal Consistency Fund $100,000
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $98,119
93.324 State Health Insurance Assistance Program $81,480
93.747 Elder Abuse Prevention Interventions Program $81,260
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $73,377
16.540 Juvenile Justice and Delinquency Prevention $69,673
16.015 Missing Alzheimer's Disease Patient Assistance Program $64,160
93.945 Assistance Programs for Chronic Disease Prevention and Control $44,612
93.197 Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $29,918
93.041 Special Programs for the Aging, Title Vii, Chapter 3, Programs for Prevention of Elder Abuse, Neglect, and Exploitation $25,713
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $25,654
90.404 Hava Election Security Grants $24,465
16.812 Second Chance Act Reentry Initiative $21,756
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $19,415
10.578 Wic Grants to States (wgs) $10,726
93.334 The Healthy Brain Initiative: Technical Assistance to Implement Public Health Actions Related to Cognitive Health, Cognitive Impairment, and Caregiving at the State and Local Levels $10,185
14.276 Youth Homelessness Demonstration Program $9,420
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $6,429
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $5,576
16.575 Crime Victim Assistance $5,045
93.304 Racial and Ethnic Approaches to Community Health $1,525
93.758 Dental Sealant Project $470
93.569 Community Services Block Grant $-3,788
93.590 Community-Based Child Abuse Prevention Grants $-37,046
93.670 Child Abuse and Neglect Discretionary Activities $-536,931