Finding Text
U.S. Department of Housing and Urban Development
Passed through the Missouri Department of Mental Health
Continuum of Care Program, Federal Assistance Listing No. 14.267
Federal award year 2024
Criteria: The OMB Compliance Supplement and terms of the grant agreements include level of effort requirements, where the recipient is required to use grant funds to supplement and not supplant other funds, when providing assistance to homeless persons or persons at risk of homelessness.
Condition: The Organization did not consistently provide documentation providing evidence of the individual’s qualifications for receiving rent and/or utility assistance prior to March 2024. Supporting documentation for some payments only included evidence of payment made to the landlord and/or utility company, but documentation was not consistently available that supported the tenant’s eligibility to receive these assistance payments. In addition, the Organization did not consistently retain documentation providing evidence of review and approval by the Organization’s staff prior to payment or drawdowns prior to March 2024. Supporting documentation for some individuals included evidence of a rental agreement in existence between the tenant and landlord, but documentation was not consistently retained that supported the Organization’s review and approval of these tenant support payments prior to March 2024.
Cause: A lack of available documentation, as well as documentation with evidence of review for periods prior to March 2024.
Effect or potential effect: The potential effect is that the Organization is not in compliance with grant requirements.
Questioned costs: None.
Context: Starting in March of 2024, management implemented internal controls over the maintenance of documentation to provide evidence of a tenant’s qualification for receiving these funds. Prior to March of 2024, no clear documentation was maintained to provide evidence of controls in place over compliance with the level of effort requirement. Management discussed reports that are reviewed when processing payments for tenants, but documentation providing evidence of these reviews and approvals was not consistently available for each selection for reperformance.
Identification as a repeat finding, if applicable: This is a repeat finding. The prior year audit finding reference number is 2023-003.
Recommendation: We recommend the Organization continue to follow its implemented system of internal controls that began in March of 2024 to ensure all relevant documentation is retained to support the payments made with the grant funds.
Views of responsible officials and auditee: Management agrees with this finding. This finding was identified during the 2023 fiscal year audit. Federal regulations govern repeat finding language, the responsible staff immediately took action to correct once identified during the fiscal year 2023 audit process.