Finding 540746 (2024-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-03-30

AI Summary

  • Core Issue: Interfaith Residence d/b/a Doorways failed to submit the required CAPER report within the 90-day deadline after the operating year.
  • Impacted Requirements: This non-compliance violates the reporting requirements set by the U.S. Department of Housing and Urban Development under 24 CFR 574.520.
  • Recommended Follow-Up: Management should establish controls and processes to monitor reporting deadlines and ensure timely submissions in the future.

Finding Text

Finding 2024-001 – Significant Deficiency: Reporting – Compliance and Control Finding ALN 14.241 – Housing Opportunities For Persons With AIDS (H.O.P.W.A.) Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: None Criteria Or Specific Requirement: Pursuant to 24 Code of Federal Regulations 574.520, Interfaith Residence d/b/a Doorways is required to submit an annual report. Per the Uniform Guidance, this report is HUD-4155 H.O.P.W.A. Consolidated Annual Performance Report(APR)/Consolidated Annual Performance and Evaluation Report (CAPER). The report is to be submitted no later than 90 days after the close of the program or operating year. Condition: Interfaith Residence d/b/a Doorways did not submit the CAPER within 90 days after the close of the operating year. Cause: The delay in the submission was due to the staffing/capacity issues caused by the unanticipated absorption of work from the sudden closing of the Outstate Missouri program’s long-time subrecipient. The additional responsibilities combined with internal staff turnover resulted in an unusual amount of time to ensure key data for the CAPER was accurate and comprehensive. Controls over compliance were not put in place by management as it relates to this compliance requirement. Effect: Interfaith Residence d/b/a Doorways did not meet the compliance reporting requirements set forth by the U.S. Department of Housing and Urban Development. Questioned Costs: Not applicable. Context: Interfaith Residence d/b/a Doorways did not ensure guidelines from the U.S. Department of Housing and Urban Development were followed to ensure timely reporting. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management implement controls and processes to ensure that all due dates for reporting are appropriately monitored and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials: Fiscal 2024 was a highly unusual year for DOORWAYS’ H.O.P.W.A. program due to the sudden cessation of housing operations by the Outstate Missouri program’s long-time subrecipient, Spectrum Health Care, in May 2023, resulting in an early termination of the subrecipient service contract. This stoppage of service came without advance warning and necessitated that DOORWAYS, through an agreement with HUD, take over direct program operations to ensure clients living in rural Missouri did not experience a disruption in housing provision. The sudden influx of work required from absorbing direct program performance, coupled with internal staff turnover in the position that oversees this program, led to reduced department capacity and oversight of the Consolidated Annual Performance and Evaluation Report (CAPER) filing. Management recognized the need for additional staff capacity to administer all required duties and hired an Outstate Program and Grants Manager on February 1, 2025 to focus on these tasks. The position is overseen by the Director of Government Grants and Compliance, who is knowledgeable about the service and reporting requirements of this program. Additionally, starting in February 2025, the team implemented bi-monthly meetings to update the Chief Financial Officers on progress and timely filing of all grants related reporting to ensure all deadlines are met.

Corrective Action Plan

Finding 2024-001 Personnel Responsible for Corrective Actions: Megan Robinson, Chief Financial Officer and Carrie Bagwell, Director of Government Grants and Compliance Anticipated Completion Date: February 2025 Corrective Action Plan: Management recognized the need for additional staff capacity to administer all required duties and hired an Outstate Program and Grants Manager on February 1, 2025 to focus on these tasks. The position is overseen by the Director of Government Grants and Compliance, who is knowledgeable about the service and reporting requirements of this program. Additionally, starting in February 2025, the team implemented bi-monthly meetings to update the Chief Financial Officers on progress and timely filing of all grants related reporting to ensure all deadlines are met.

Categories

Subrecipient Monitoring HUD Housing Programs Reporting Significant Deficiency

Other Findings in this Audit

  • 540747 2024-001
    Significant Deficiency
  • 540748 2024-001
    Significant Deficiency
  • 540749 2024-001
    Significant Deficiency
  • 540750 2024-001
    Significant Deficiency
  • 1117188 2024-001
    Significant Deficiency
  • 1117189 2024-001
    Significant Deficiency
  • 1117190 2024-001
    Significant Deficiency
  • 1117191 2024-001
    Significant Deficiency
  • 1117192 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.241 Housing Opportunities for Persons with Aids $963,556
93.917 Hiv Care Formula Grants $751,778
14.267 Continuum of Care Program $436,093
93.928 Special Projects of National Significance $341,225
21.027 Coronavirus State and Local Fiscal Recovery Funds $79,446
14.218 Community Development Block Grants/entitlement Grants $78,375
14.231 Emergency Solutions Grant Program $61,759
93.914 Hiv Emergency Relief Project Grants $14,874