Diocese of Camden
Single Audit Corrective Action Plan
For the Fiscal Year Ended June 30, 2023 Re-submitted: November 25, 2024
Wipfli LLP
1502 London Road, Suite 200
Duluth, MN 55812
Attn: Michelle Swoboda, CPA FEDERAL AWARD FINDING
U.S. Department of Housing and Urban Development Emergency Solutions Grant Program AL# 14.231 Passed through State of New Jersey Department of Community Affairs:
Grant No. 2019 02156 036106 8/2020 3/2023
Grant No. 2022 02156 0337 00 7/2021 7/2023
Grant No. 2022 02156 0339 00 4/2022 7/2023
Grant No. 2022 02156 0338 00 4/2022 9/2023
Grant No. 2022 02156 0052 08 12/2019 9/2023
Grant No. 2020 02156 0042 08 12/2019 9/2023
Grant No. 2020 02156 0042 04 12/2019 9/2023
Grant No. 2019 02156 0361OS 12/2018 9/2023
2023-003 - Activities Allowed and Allowable Costs (Significant Deficiency)
Statement of Condition
Supportive service expenditures were processed and paid for ineligible participants.
Criteria
ESG funds may be used for five program components: street outreach, emergency shelter, homelessness prevention, rapid re-housing assistance, and HMIS; as well as administrative activities. The five program components and the eligible activities that may be funded under each are set forth in 24 CFR 576.101 through 576.107.
Cause
Due to lack of supervisory oversight, several employees falsified participant documents whereby ineligible individuals
with personal relationships to these employees receive assistance payments.
Effect
Management became aware of the improprieties and hired an independent forensic investigator. The forensic investigator identified improper disbursements to ineligible participants along with other disbursements that required further research, inconclusive, insufficient, unverified, and LLC discrepancy disbursements. Management also notified the State of New Jersey Department of Community Affairs Office of Auditing.
Recommendation
Management should strengthen controls over documentation required for participants to receive assistance payments along with controls over review of documentation in participant files and processing of these payments.
www.catholiccharitiessouthjersey.org
1845 Haddon A\-enue, Camden, NJ 08103 I Tel: 856•342-4100 I Fu: 856---3424180
Serving si.,;: counties of Southern Nev,1Jersey: Atlantic, Camden, Cape May; Cumbedand, Gloucester & Salem
View of Responsible Officials
Management agrees with the recommendation and has begun implementing additional procedures to ensure that applicant files are complete and that case files and support are being reviewed by supervisory personnel.
Corrective Action:
The improper activity was identified in October 2023 and the following actions were subsequently taken:
• Two caseworks and a supervisor were terminated.
• The agency's Executive Director retired.
• The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements.
• The central accounting department revised the check processing procedures to ensure that the following
documentation accompanied housing related check requests:
o W-9 signed by the vendor
o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep.
o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease.
o Copy of an executed rental lease.
o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc...
o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant.
• Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department.
• Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person.
• A new Executive Director for the Organization was hired in February 2024.
• Created and filled the position of Grants Compliance Specialist. This position is responsible to:
o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding.
o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to
the agency's policies and procedures.
Mandated the universal use of ETD Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail.
Projected Completion Date
As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist
continue to review, modify and communicate policies/procedures with all case management staff.
Contact Person
Robert Waite, Controller
856-342-4186; robert.waite@camdendiocese.org
If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above.
Robert T Waite, Controller