Finding 538148 (2024-001)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-27

AI Summary

  • Core Issue: There are significant deficiencies in determining eligibility for housing assistance, leading to potential support for ineligible individuals.
  • Impacted Requirements: Missing documentation and incorrect calculations violate eligibility criteria outlined in 24 CFR 574.3.
  • Recommended Follow-Up: Management should enhance internal controls to ensure all necessary documentation is collected and eligibility calculations are accurate.

Finding Text

2024-001 – Eligibility for Housing Assistance Significant Deficiency Criteria: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person’s family, including persons important to their care and well-being, as defined in 24 CFR 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on Participant #10 (Criteria 1) 1 – Incorrect amount of support provided to Participant #10, and (Criteria 1) 1 – Missing documentation of lease contract for Participant #6 (Criteria 2) Cause: WNCAP personnel miscalculated Participant #10's income, which resulted in the incorrect amount of support being provided. The landlord for Participant #6 refused to provide the lease agreement. Effect: Compliance with eligibility could not be determined for some sampled tenants. Therefore, some ineligible individuals may have received assistance under the program. Some individuals received the incorrect amount of support. Questioned Costs: Undeterminable Context: During the year, 85 unique clients were served. We sampled 20 tenant files for multiple compliance requirements. Identification of a Repeat Finding: Criteria 2 is a repeat finding from the immediate previous audit, 2023-001. Recommendation: Management should implement internal control procedures to ensure that all required documentation for determining eligibility is obtained and included in each tenant file. Management should also ensure that eligibility for assistance is properly calculated. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.

Corrective Action Plan

2024-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on client DNSE 1 – Incorrect amount of support provided to DNSE, and 1 – Missing documentation of lease contract for client AGFA Corrective Action: Section 1 RE: Incorrect Rental Calculation & Incorrect amount of support paid to landlord: WNCAP will continue utilizing the eligibility checklist implemented with the 2022 corrective action plan, as it has resulted in the significant reduction of errors, as evidenced by the continued improvement in comparison to previous audits. The incorrect calculation referenced in this finding was due to a typo, which resulted in an overpayment. To catch simple human errors such as this in the future, management will update the rent calculation worksheet to include reminders to double check data entry in fields that are easy to transpose. Management will also update the recertification process to add the following additional steps: The Data Technician will also review the rent calculation worksheet and the supporting documentation to ensure the amounts in the supporting document(s) match the entry in the worksheet; the Housing Coordinator will conduct a randomized audit of at least two rent calculation worksheets each month. Section 2 RE: Missing documentation of lease contract. WNCAP management will confer with state grant monitors to create and implement a zero-tolerance policy that abates payments immediately if a landlord or client does not provide the documents necessary for recertification in a timely manner. Unfortunately, this will likely result in some evictions and may jeopardize WNCAP’s ability to recruit landlords in a highly competitive market, but there is no guidance on any alternatives that would preserve housing stability as long as possible while still being considered compliant. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2022-23 audit: 2022-23 Total Deficient Eligibility Records: 8 2023-24 Total Deficient Eligibility Records: 3 WNCAP expects to see continued improvement in subsequent audits.

Categories

Eligibility Significant Deficiency

Other Findings in this Audit

  • 1114590 2024-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.241 Housing Opportunities for Persons with Aids $846,345
93.917 Hiv Care Formula Grants $196,768
93.940 Hiv Prevention Activities Health Department Based $160,772
93.488 National Harm Reduction Technical Assistance and Syringe Services Program (ssp) Monitoring and Evaluation Funding Opportunity $94,306
93.361 Nursing Research $64,694