Finding Text
2024-001
Federal Agencies:
U.S. Department of Housing and Urban Development
Federal Program Names:
HOME Investment Partnership Program
Assistance Listing Numbers:
14.239
Pass-Through Agencies:
City of Philadelphia, Redevelopment Authority:
Venango – Loan
Thompson Street – Loan
County of Schuylkill - Home Investment Partnerships and Housing Trust Funds Programs: Fountain Springs - Loan
Mayor and City of Baltimore:
Baltimore Housing - Park Heights Women and Children - Loan
Award Period: July 1, 2023 through June 30, 2024
Type of Finding: Material Witness in Internal Control over Compliance
Criteria:
3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provision of eligibility. The Organization should have procedures and controls in place to ensure that the Organization leases the property to low-income homeless persons and complies with the terms and conditions dictated in the HOME loan agreement. Proper documentation should be maintained demonstrating evidence that residents living at the property meet the HOME loan criteria.
Condition:
As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless), and lease or housing agreement (depending on program requirements). Of the 40 resident client files reviewed, management was unable to provide any proof of income or determination of homelessness or residency for 24 files.
Questioned costs:
None
Context:
The HOME program has income targeting requirements where only low-income or very low-income individuals, as defined in 24 CFR section 92.2, are eligible for housing assistance. Consequently, organizations receiving or using HOME funds must verify the annual income of each household, considering all members. These organizations must maintain records for every family assisted. HOME-assisted units in rental housing projects must be occupied only by households that qualify as low-income families and must adhere to specific rent limits. According to 24 CFR Section 92.209(c), participating organizations must select families based on low-income or homeless criteria.
Cause:
The Organization’s residential program, Philly House, which operated from the Venango location, provided low-intensity residential services for adult men with substance use and co-occurring disorders. This program was relocated to another site within the Organization’s network as it better complied with the requirements specified in the Project HOME Loans due to its nature.
In contrast, the Re-Entry House, a halfway house for adult men with substance use and co-occurring disorders offering stable residential housing services, represented a different type of residential program. During the transition, management, at the location, did not prepare policies and procedures to determine income eligibility as outlined in the Project Home Loan agreement and 24 CFR section 92.2. Consequently, no documentation was prepared or provided to the auditors to demonstrate compliance with the eligibility and Project HOME Loan requirements.