Finding 537283 (2024-001)

Significant Deficiency
Requirement
ABEH
Questioned Costs
-
Year
2024
Accepted
2025-03-26

AI Summary

  • Core Issue: UWMC lacks effective internal controls over monitoring partner agencies for ERAP funding eligibility.
  • Impacted Requirements: Federal guidelines for documentation and eligibility verification are not consistently met by partner agencies.
  • Recommended Follow-Up: UWMC should work with partner agencies to align documentation practices with federal standards and require attestation of compliance before reimbursement.

Finding Text

Criteria: United Way of Monterey County (“UWMC”) must establish and maintain effective internal controls over subrecipient monitoring of Emergency Rental Assistance Program (ERAP) federal awards with pass through agencies, contracted with UWMC to assist in administering ERAP awards. Condition: UWMC contracts with partner agencies to determine eligibility and distribute ERAP funding. UWMC depends on these partner agencies to thoroughly review and maintain appropriate documentation verifying the eligibility of recipients for ERAP funding. Cause: During the single audit for the fiscal year ending June 30, 2024, a partner agency failed to provide documentation verifying the eligibility of one recipient for ERAP funding. Effect: There may be end recipients that did not meet the eligibility requirements to receive ERAP funding. Recommendation: We recommend that UWMC collaborate with partner agencies to ensure their control documentation requirements align with federal guidelines. This will help guarantee that federal funds are accurately accounted for and that partner agencies maintain proper controls over the required documentation for approved ERAP recipients. Additionally, partner agencies should be required to attest to meeting all documentation requirements before reimbursement. Management’s Response: In response to this finding, the Vice President of Finance is responsible for oversight of future monitoring visits with partners who receive federal direct financial assistance. There will be an ERAP closeout monitoring visit done with all ERAP partners who received direct financial assistance since the inception of the ERAP program to verify their record and retention procedures. Any record of noncompliance will be documented accordingly.

Corrective Action Plan

The Emergency Rental Assistance Program was developed in response to the pandemic and was implemented swiftly to meet the needs of low-income tenants affected by Covid-19. The program design involves fourteen partner agencies and their varying accounting systems. In the current fiscal year, all partnering agencies were required to submit program data through the online Neighborly software along with providing a general ledger report that supports and is reconciled to the data submitted prior to receiving reimbursement. In response to the compliance finding for our June 30,2024 Single Audit, United Way Monterey County will implement a year end ERAP closeout with all partners who received direct financial assistance. There will be monitoring visits done by the Vice President of Community Investments. Any record of noncompliance will be documented accordingly. The UWMC staff member overseeing these monitoring visits for us is: Josh Madfis VP, Community Investments Josh.madfis@unitedwaymcca.org (831) 372-8026

Categories

Subrecipient Monitoring Internal Control / Segregation of Duties Cash Management Eligibility

Other Findings in this Audit

  • 1113725 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.023 Emergency Rental Assistance Program $2.44M
94.006 Americorps State and National 94.006 $331,203
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $57,193
93.569 Community Services Block Grant $55,500