Finding 576312 (2024-002)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-09-12

AI Summary

  • Core Issue: YNHA failed to consistently document eligibility and recertification for housing assistance, leading to potential compliance risks.
  • Impacted Requirements: Lack of signed rental agreements and approval evidence for recertifications and inspections violates HUD guidelines and internal control standards.
  • Recommended Follow-Up: YNHA should establish written procedures and conduct staff training to ensure all necessary documentation is collected and maintained.

Finding Text

Program Information: U.S. Department of Housing and Urban Development Indian Housing Block Grant Assistance Listing #14.867 Award Numbers: 55-IH-53-18320 Award Period: 10/18/2011 – 09/30/2034 Criteria: Per the 2024 OMB Compliance Supplement, each recipient shall develop written policies governing the eligibility, admission, and occupancy of families for housing assisted with grant funds (25 USC 4133(d)). Per YNHA policies, all program applicants must meet the following eligibility requirements: • Qualify as an Indian Family or qualify for an exception - YNHA may decide to provide housing assistance for non-Indian family if they deem the presence of the family on the reservation is essential to the well-being of Indian families and the need for housing of essential families cannot reasonably be met without such assistance (ex. teachers, healthcare providers). Executive Director will make a determination for essential families. YNHA may also provide housing for law enforcement officers of the Nation or another unit of government and YNHA determines the presence of the officer may deter crime. • Have an annual income that meets income eligibility standards (considered low-income based on HUD thresholds) or qualify as an exception. Families that are not low-income can receive assistance in a few cases: they were low income at the time of initial occupancy, they received a Mutual Help unit through transfer of the unit from a family member, or the family is an essential family/law enforcement (see above). • Be 18 years or older or 16 with status as an emancipated minor. • Provide a complete application including proof of tribal enrollment, social security cards, and proof of income. • Signed Consent for Release of Information to YNHA/HUD Form 9886. • Must submit to drug and alcohol screening tests prior to signing the rental agreement, lease, or homeownership agreement. • Annual inspections. 2 CFR § 200.303 - Internal controls states, the non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During testing of 30 tenant files under the IHBG program: • 2 of 30 files did not include a signed rental agreement documenting initial eligibility approval. • 30 of 30 files lacked evidence of approval of recertifications or required inspections. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: YNHA’s internal control procedures over eligibility and recertification were not consistently followed. Management did not ensure that signed agreements and approvals of recertifications/inspections were documented in the tenant files. Effect: Failure to document eligibility determinations and approvals creates a risk that ineligible tenants may receive housing benefits, that federal program requirements may not be met, and that YNHA may be subject to HUD compliance findings. Questioned Cost: N/A – The documentation deficiencies identified did not result in known unallowable costs or payments to ineligible participants; therefore, no questioned costs are reported. Prior Year Finding: No. Recommendation: We recommend that YNHA implement written procedures and staff training to ensure all required eligibility and occupancy documentation is obtained and retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Persons responsible for this corrective action plan: Phylistine Alexander, Housing Manager and Jana Kent, Executive Director Corrective Action Plan: YNHA will work with the NwONAP Grant Evaluation Director to evaluate our current tenant file documentation and eligibility determination process and will implement recommendations from HUD. Estimated Completion Date: December 31, 2025

Categories

Allowable Costs / Cost Principles Eligibility HUD Housing Programs Material Weakness Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 576313 2024-003
    Significant Deficiency
  • 576314 2024-004
    Significant Deficiency
  • 1152754 2024-002
    Material Weakness
  • 1152755 2024-003
    Significant Deficiency
  • 1152756 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.865 Public and Indian Housing Indian Loan Guarantee Program $7.60M
14.867 Indian Housing Block Grant $7.47M
21.026 Covid-19 Homeowners Assistance Fund $935,956
14.899 Tribal Hud-Va Supportive Housing Program $274,835
93.568 Low-Income Home Energy Assistance $115,829
81.042 Weatherization Assistance for Low-Income Persons $103,802
81.U01 Energy Weatherization $20,153
14.870 Resident Opportunity and Supportive Services - Services Coordinators $12,650