Finding Text
Eligibility
Low-Income Home Energy Assistance ALN# 93.568
US Department of Health and Human Services
Passed through Oregon Housing and Community Services
Federal Grant/Contract Number: 2021ORLIEA, 2022ORLIEA, 2102ORE5C, 2101ORLWC5, 2102ORLWC6
Grant period – 2021 & 2022
Criteria – Per the 2021-2023 Master Grant Agreement. Subgrantee shall, and shall cause and shall require its subrecipients by contract to administer the program in a manner satisfactory to OHCS and in compliance with all program requirements, including but not limited to the following terms and conditions:
(4) Serve only households whose eligibility has been determined in compliance with program requirements.
(8) Be responsible for maintaining an internal controls framework, satisfactory to OHCS, which assures compliance with program requirements.
(11) Maintain other program records satisfactory to the department, which document, among other things, client eligibility requirements, receipt of allowable program services, termination of services and the basis for same, housing and income status of clients, administrative actions, contracts with subcontractors, review of subcontractor performance, action taken with respect to deficiency notices, and any administrative review proceedings. Such records shall be in substance and format satisfactory to the department.
Condition – In our sample of 60 items, we noted the following exceptions:
• 3 instances where client applications could not be produced
• 1 instance where client application did not contain evidence of a bill
• 6 instances where the combo payment amount covering overages of another program could not be substantiated in terms of amount paid
• 1 instance where crisis payment didn’t contain all elements of documentation required for amount paid
• 4 instances where bulk fuel payments didn’t contain all elements of documentation required for information taken via quote or vendor
The Agency was not able to provide a listing of payments made on behalf of clients corresponding to the fiscal year, and we were unable to reconcile the awards paid out to the cash received from the passthrough entity and the listing of applications approved during the year.
Cause – Supporting applications and required documentation were not retained by the Agency to substantiate eligibility and services provided.
Effect – Applicants could receive improper benefit amounts based on eligibility criteria, excessive disbursements could be made, and a return of funds could be required to grantor.
Questioned Costs – $190,142, based on the populations sampled.
Recommendation – Documentation should be prepared, reviewed, and retained to support the period of performance and earmarking. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate.
Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.