Finding 523548 (2023-003)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2025-02-18

AI Summary

  • Core Issue: There is a significant weakness in internal controls, leading to material noncompliance with the Housing Assistance Fund Program requirements.
  • Impacted Requirements: Missing debt verification documentation for 13 out of 40 participants raises concerns about compliance with funding eligibility criteria.
  • Recommended Follow-Up: PHFA should enhance procedures for obtaining and verifying debt documentation during the HAF application process.

Finding Text

Federal Agency: U.S. Department of Treasury Federal Program Name: Housing Assistance Fund Program Assistance Listing Number: 21.026 Federal Award Identification Number and Year: Various Award Period: 7/1/2022 – 6/30/2023 Type of Finding:  Material Weakness in Internal Control over Compliance, Material Noncompliance (Qualified Opinion) Criteria or specific requirement: Per the compliance supplement, agencies may provide Housing Assistance Fund Program (“HAF”) funds only to a homeowner with respect to qualified expenses related to the dwelling that is such homeowner’s primary residence. In order to substantiate the disbursement of funds, debt verification is required to be obtained from the vendor to ensure the applicant is delinquent on the qualified expense and to confirm the amount. Condition: During our testing, 13 of 40 participants did not have the required debt verification documentation in their case file. Questioned costs: Unknown Context: In a statistically valid sample, we noted that 13 of 40 HAF participant files were missing a debt verification form in their case file. The form exists as a way to document the participant’s residence. Cause: The subcontractor who administered the HAF program through February 2023 was unable to provide debt verification for all of the applicant files processed by the subcontractor. Effect: There is not definitive proof that HAF disbursement was in accordance with policy nor accurate. Repeat Finding: Not a repeat finding. Recommendation: We recommend that PHFA review their procedures around the debt verification during the HAF program application process. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Treasury Housing Assistance Fund Program – Assistance Listing No. 21.026 Recommendation: CLA recommended that PHFA review their procedures around the debt verification during the HAF program application process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Based on this and other similar inadequacies with the vendor, the Agency terminated the contract of the non-compliant vendor (IEM) and moved the administration of the program in house. The new procedures and software being utilized provide the required documentation and verification to support disbursements as evidenced by the audit review. The Agency also anticipates making a mandatory discovery demand for all supporting program documentation to include the debt verification data and will seek judicial enforcement if IEM does not comply with the request. Name of the contact person responsible for corrective action: Kelly Wilson, PAHAF Program Manager. Planned completion date for corrective action plan: The migration to in house administration was completed in March of 2023. The discovery request is expected to be made by no later than Monday, March 25th, 2024.

Categories

Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 523546 2023-002
    Significant Deficiency
  • 523547 2023-001
    Significant Deficiency
  • 1099988 2023-002
    Significant Deficiency
  • 1099989 2023-001
    Significant Deficiency
  • 1099990 2023-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.195 Project-Based Rental Assistance (pbra) $513.61M
14.239 Home Investment Partnerships Program $196.70M
21.026 Homeowner Assistance Fund $118.50M
14.275 Housing Trust Fund $35.80M
21.027 Coronavirus State and Local Fiscal Recovery Funds $16.82M
10.438 Section 538 Rural Rental Housing Guaranteed Loans $3.00M
21.011 Capital Magnet Fund $2.77M
66.458 Clean Water State Revolving Fund $2.11M
14.326 Project Rental Assistance Demonstration (pra Demo) Program of Section 811 Supportive Housing for Persons with Disabilities $1.94M
99.U19 Housing Stability Counseling Program $1.77M
14.169 Housing Counseling Assistance Program $1.50M