Finding 564124 (2024-002)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-06-06
Audit: 358229
Auditor: Hw&co

AI Summary

  • Core Issue: Inadequate verification of income and poor documentation of eligibility for rental assistance applicants.
  • Impacted Requirements: Non-compliance with the Emergency Rental Assistance (ERA) Program guidelines set by the U.S. Treasury.
  • Recommended Follow-Up: Review and enhance procedures to ensure proper documentation is maintained for all applicants' eligibility.

Finding Text

Condition: Controls in place did not appropriately verify income for an applicant and documentation of eligibility was not adequately maintained. Criteria: The Organization is required to comply with the requirements of the Emergency Rental Assistance (ERA) Program. The Organization is required to design and implement controls to ensure financial assistance payments meet the criteria set forth by the U.S. Treasury, appropriately documenting household eligibility, including the verification of income. Cause: While the Organization had procedures in place to verify eligibility, appropriate documentation was not maintained for certain applicants. Effect: The Organization risked providing emergency rental assistance to applicants who were not eligible. Context: Out of a sample of 25 assistance case numbers selected for eligibility testing, 1 sample was missing adequate documentation of income verification. Questioned Costs: N/A Recommendation: We recommend the Organization review its procedures and controls to ensure appropriate documentation is maintained for the eligibility of recipients of the program. Views of Responsible Officials and Planned Corrective Actions: The Organization acknowledges the finding to review their procedures around appropriate documentation for eligibility of recipients for the program and management has met to implement corrective action effective April 2025. The Organization has implemented policies and procedures which include additional reviews and approvals of income verification prior to rental assistance disbursement, and an expansion of its internal audit process. See The Organization’s Corrective Action Plan for further details.

Corrective Action Plan

Comments on the Finding and Each Recommendation – We acknowledge the finding to review our procedures around appropriate documentation for eligibility of recipients for the program. We plan to verify eligibility for all clients through income verification and include enhanced audit processes in our supervisory review prior to signing off of files for submission to accounts payable for processing going forward. This enhanced process includes a signoff on the check request cover sheet, implemented in April 2025, as verification of the review of the income verification being completed at the time of file review. All files in support of income verification get scanned into our Salesforce software as documentation with client files. We further plan to increase our internal audits of files to 10 a month, selecting a sample across counselors each month. This process will include a review of income verification completed within each file. Finally, we will be including an internal quality improvement monitor in our QI committee to track progress on these efforts. Actions Taken on the Finding – By taking these steps we aim to fully resolve this issue and establish a more robust and transparent process to ensure proper documentation of eligibility for the remainder of this grant.

Categories

Eligibility

Other Findings in this Audit

  • 564123 2024-001
    Significant Deficiency
  • 1140565 2024-001
    Significant Deficiency
  • 1140566 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $6.37M
21.023 Emergency Rental Assistance Program $5.99M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $665,915
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $267,654
93.747 Elder Abuse Prevention Interventions Program $254,931
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $191,539
93.791 Money Follows the Person Rebalancing Demonstration $152,120
93.052 National Family Caregiver Support, Title Iii, Part E $148,584
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $104,596
14.169 Housing Counseling Assistance Program $83,114
14.218 Community Development Block Grants/entitlement Grants $62,859
93.969 Pphf Geriatric Education Centers $50,935
93.788 Opioid Str $30,000
99.U19 Housing Stability Counseling Program $22,500
93.866 Aging Research $17,084
93.958 Block Grants for Community Mental Health Services $13,874
93.470 Alzheimer’s Disease Program Initiative (adpi) $9,054