Finding 523678 (2022-003)

Material Weakness
Requirement
ABL
Questioned Costs
$1
Year
2022
Accepted
2025-02-19

AI Summary

  • Core Issue: There was material noncompliance with federal program requirements due to fraudulent expenditures.
  • Impacted Requirements: Compliance with activities allowed, allowable costs, and reporting standards was not met.
  • Recommended Follow-Up: Redefine the accounting and control system to prevent future fraud.

Finding Text

Information on the Federal Program: Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of the Treasury. Pass-Through Entities: State of Delaware and City of Dover, Delaware. Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Reporting. Type of Finding: Material Noncompliance. Criteria: Program requirements state that a grantee may use funds for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021. Condition: For the year ended December 31, 2022, we reviewed support for program expenditures and noted that certain support produced and submitted to the recipient were fraudulent. Cause: A breakdown in internal controls, further discussed in Note M to the financial statements enabled the fraudulent misappropriation of program funds. Effect or Potential Effect: As a result, the Organization is not in compliance with program requirements for the year ended December 31, 2022. Questioned Costs: $13,600 Context: Of the $637,174 of federal expenditures relating to this program, $13,600 represented fraudulent expenditures. All fraudulent expenditures relating to this program took place within the Health Services Grant received as a subrecipient through the City of Dover, Delaware. Recommendation: Whisman, Giordano & Associates recommendation is to redefine the entire accounting and control system.

Corrective Action Plan

Fraud was identified by board members of the Dover Interfaith Mission for Housing (DIMH) in November 2023 with respect to the Emergency Housing and Health programs, and an internal investigation ensued. Prior to this finding, a committee of the board reviewed the Executive Director’s (ED) financial reporting and were confident in her documentation, which was also approved by the City of Dover manager of the Emergency Housing and Health programs. Briefly, the ED had invented invoices from motels and landlords along with applications from individuals and families who did not exist. In both programs, DIMH provided funds to cover motel stays and landlord payments and was reimbursed by the City of Dover. In practice, the ED simply took DIMH funds, deposited them into a personal account, and provided invented documents to the City that resulted in reimbursement to DIMH. This clever ruse had eluded both board and city personnel monitoring the expenditures and reimbursements. Once there was suspicion of fraud, board members not involved in prior program oversight actively reviewed files with the City’s program manager to ascertain its extent. A meeting was held between the board chair and the city’s program manager to review all files in order to determine the approximate extent of the fraud, which was clearly limited to these two grant programs. In early January 2023, DIMH board members arranged to meet with the Dover Police Department to provide an overview of the fraud. This led to police contact with local FBI and HUD inspector general offices along with the US attorney for Delaware, with the same board members providing all files and in-person descriptions of the scam. These agencies continued to work on uncovering the details of the case and are expected to meet with the former ED on February 28, 2025. In early 2024, the DIMH board engaged a new external accounting firm and created a new control environment with significant internal controls and separation of duties developed in collaboration with the contracted CPA firm.

Categories

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 523677 2022-002
    Material Weakness
  • 1100119 2022-002
    Material Weakness
  • 1100120 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.569 Community Services Block Grant $99,698
14.218 Community Development Block Grants/entitlement Grants $54,087
21.027 Coronavirus State and Local Fiscal Recovery Funds $13,600