Finding 577292 (2022-002)

2022-002 – Eligibility for Housing Assistance Significant Deficiency Criteria: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person’s family, including persons important to their care and well-being, as defined in 24 CFR 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 14 – Missing Release of Information documentation, 9 -- Missing documentation of client and/or landlord participation agreements, 4 -- Missing documentation of current income or verification of 0 income, 3 – Missing documentation of housing plan or assessment. Cause: The shift to remote work and varying levels of technical knowledge among staff on digital record keeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten. In addition, WNCAP was in the process of implementing Electronic Health Records (Apricot) when the COVID crisis began. Effect: Compliance with eligibility could not be determined for some sampled tenants. Therefore, some ineligible individuals may have received assistance under the program. Questioned Costs: Undeterminable Context: During the year, 113 unique clients were served. We sampled 22 tenant files for multiple compliance requirements. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-003. Recommendation: Management should implement internal control procedures to ensure that all required documentation for determining eligibility is obtained and included in each tenant file. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.