Finding 50468 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 45210
Organization: Home Forward (OR)

AI Summary

  • Core Issue: Home Forward failed to collect required certified payrolls from a contractor before making payments on a contract subject to wage rate requirements.
  • Impacted Requirements: Compliance with federal wage rate requirements was not met, as outlined in multiple regulations including 29 CFR sections 5.5 and 5.6.
  • Recommended Follow-Up: Home Forward should review and strengthen their internal controls and processes for managing contracts with wage rate requirements to ensure future compliance.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: OR02VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Wage Rate Requirements Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Home Forward must do the following: ? As a condition to executing payment for a contract subject to wage rate requirements, require the contractor to submit to them weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: Home Forward provided payment for a contractor agreement that included wage rate requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 1 out of 5 contracts tested for wage rate requirements: ? Payment was made on a contract for which certified payrolls were required but not submitted. The sample was statistically valid. Cause: Home Forward did not follow the established procedures for payment of construction contracts subject to wage rate requirements. Effect: Home Forward is not in compliance with wage rate requirements. Repeat Finding: No. Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requirements. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Housing and Urban Development 2022-01 Moving to Work Demonstration Program ? Assistance Listing No. 14.881 Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Home Forward?s Procurement group will add an additional layer of contract review to the department?s quarterly review process. Procurement will begin review of the activity input into the agency?s certified payroll reporting system to compare to the payments made to contractors withing the period. Any payment activity will be cross referenced with the certified payroll to ensure receipt of Davis Bacon reporting has been submitted. Procurement will work with the Property Management group to resolve any items that require follow up with the contractors as a result of the review. Name(s) of the contact person(s) responsible for corrective action: Elise Anderson Planned completion date for corrective action plan: 12/31/2023.

Categories

Special Tests & Provisions HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 50469 2022-002
    Significant Deficiency
  • 626910 2022-001
    Significant Deficiency
  • 626911 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $107.77M
14.871 Section 8 Housing Choice Vouchers $43.16M
21.023 Emergency Rental Assistance Program $21.61M
14.267 Continuum of Care Program $7.05M
21.027 Coronavirus State and Local Fiscal Recovery Funds $5.90M
14.871 Emergency Housing Vouchers $4.17M
14.879 Mainstream Vouchers $1.92M
97.024 Emergency Food and Shelter National Board Program $682,638
14.896 Family Self-Sufficiency Program $640,763
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $617,488
14.191 Multifamily Housing Service Coordinators $351,213
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $181,909
16.034 Coronavirus Emergency Supplemental Funding Program $125,837
17.259 Wia Youth Activities $86,247
14.218 Community Development Block Grants/entitlement Grants $3,650