Finding 524242 (2023-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2025-02-21
Audit: 343437
Organization: Next Move Homeless Services (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The organization failed to provide documentation proving that rental rates paid were reasonable compared to local market rates, affecting compliance with HUD regulations.
  • Impacted Requirements: Noncompliance with 24 CFR sections 578.49(b)(1) and (2), leading to potential overpayments exceeding HUD's fair market rents.
  • Recommended Follow-Up: Strengthen policies and procedures to ensure ongoing compliance with rental rate assessments, as this is a repeat finding from 2022.

Finding Text

Program: Continuum of Care Federal Financial Assistance Listing No.:14.267 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward Award Year: 2023 Compliance Requirement: Special Tests and Provisions – Reasonable Rental Rates Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208 Type of Finding: Material Weakness in Internal Controls Over Compliance and Material Noncompliance Criteria: Per 24 CFR section 578.49(b)(1), where grants are used to pay for rent for all or a part of a structure, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space. Per 24 CFR sections 578.49(b)(2) and 578.51(g) and (j), where grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units taking into account relevant features. In addition, the rents may not exceed rents currently being charged by the same owner for comparable unassisted units, and the portion of rents paid with grant funds may not exceed HUD-determined fair market rents. Grant funds in an amount up to one month’s rent may be used to pay the non-recipient landlord for any damages to leased units by homeless participants. Condition Found: • As a result of our procedures performed, we noted for 8 out of 17 rental participants tested, the organization could not provide documentation to demonstrate the reasonableness of contract rents being paid for individual housing units in relation to rents being charged for comparable units. This should have included an analysis of rents in the immediate area of the participants housing. • For 3 out of 41 rental payments tested, we noted the rent paid exceed the HUD-determined fair market rents for the fiscal year. Cause: The Organization was applying a method of determining reasonable rents that had been allowable under prior awards, prior to migration of the program's funding to the Continuum of Care program under assistance listing number 14.267. Effect: Rent paid to landlords on behalf of participants may have been higher in comparison to other rental properties in a similar area during the period the reasonableness assessment was not completed. Also, rental payments made using grant funds exceeded the HUD-determined fair market rents. Questioned Costs: $330 in questioned costs was identified as a result of our procedures. Context/ Sampling: • A nonstatistical sample of 17 out of 109 participants was selected to test for rent reasonableness documentation. • A nonstatistical sample of 41 out of 1,088 rental payments were selected to test compliance over the HUD-determined fair market rents. Our sample was $59,905 in rental payments and the population of rental payments for the year ended December 31, 2023 totaled $2,491,614.94. Repeat Finding from Prior Years: Yes, Finding 2022-002 Recommendation: This is a repeat finding from 2022. It was noted that the Organization implemented procedures in January 2022 to document rent reasonableness checks on a prospective basis, however this was not corrected for the samples tested as part of our audit. We recommend that the Organization continue to implement policies and procedures to ensure compliance with the program’s Special Tests and Provisions – Reasonable Rental Rates requirement. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

Categories

Questioned Costs Special Tests & Provisions HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 524240 2023-002
    Material Weakness Repeat
  • 524241 2023-002
    Material Weakness Repeat
  • 524243 2023-002
    Material Weakness Repeat
  • 524244 2023-002
    Material Weakness Repeat
  • 524245 2023-002
    Material Weakness Repeat
  • 524246 2023-003
    Material Weakness Repeat
  • 524247 2023-003
    Material Weakness Repeat
  • 524248 2023-003
    Material Weakness Repeat
  • 524249 2023-003
    Material Weakness Repeat
  • 524250 2023-003
    Material Weakness Repeat
  • 524251 2023-003
    Material Weakness Repeat
  • 524252 2023-003
    Material Weakness Repeat
  • 524253 2023-003
    Material Weakness Repeat
  • 1100682 2023-002
    Material Weakness Repeat
  • 1100683 2023-002
    Material Weakness Repeat
  • 1100684 2023-002
    Material Weakness Repeat
  • 1100685 2023-002
    Material Weakness Repeat
  • 1100686 2023-002
    Material Weakness Repeat
  • 1100687 2023-002
    Material Weakness Repeat
  • 1100688 2023-003
    Material Weakness Repeat
  • 1100689 2023-003
    Material Weakness Repeat
  • 1100690 2023-003
    Material Weakness Repeat
  • 1100691 2023-003
    Material Weakness Repeat
  • 1100692 2023-003
    Material Weakness Repeat
  • 1100693 2023-003
    Material Weakness Repeat
  • 1100694 2023-003
    Material Weakness Repeat
  • 1100695 2023-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 Continuum of Care Program $1.07M
14.218 Community Development Block Grants/entitlement Grants $970,871
21.027 Covid -19 Coronavirus State and Local Fiscal Recovery Funds $553,386
93.558 Temporary Assistance for Needy Families $197,836
14.231 Emergency Solutions Grant Program $127,931
97.024 Emergency Food and Shelter National Board Program $71,218
10.558 Child and Adult Care Food Program $52,384
93.569 Community Services Block Grant $29,968