Finding 626910 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 45210
Organization: Home Forward (OR)

AI Summary

  • Core Issue: Home Forward failed to collect required certified payrolls from a contractor before making payments on a contract subject to wage rate requirements.
  • Impacted Requirements: Compliance with federal wage rate requirements was not met, as outlined in multiple regulations including 29 CFR sections 5.5 and 5.6.
  • Recommended Follow-Up: Home Forward should review and strengthen their internal controls and processes for managing contracts with wage rate requirements to ensure future compliance.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: OR02VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Wage Rate Requirements Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Home Forward must do the following: ? As a condition to executing payment for a contract subject to wage rate requirements, require the contractor to submit to them weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: Home Forward provided payment for a contractor agreement that included wage rate requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 1 out of 5 contracts tested for wage rate requirements: ? Payment was made on a contract for which certified payrolls were required but not submitted. The sample was statistically valid. Cause: Home Forward did not follow the established procedures for payment of construction contracts subject to wage rate requirements. Effect: Home Forward is not in compliance with wage rate requirements. Repeat Finding: No. Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requirements. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Special Tests & Provisions HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 50468 2022-001
    Significant Deficiency
  • 50469 2022-002
    Significant Deficiency
  • 626911 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $107.77M
14.871 Section 8 Housing Choice Vouchers $43.16M
21.023 Emergency Rental Assistance Program $21.61M
14.267 Continuum of Care Program $7.05M
21.027 Coronavirus State and Local Fiscal Recovery Funds $5.90M
14.871 Emergency Housing Vouchers $4.17M
14.879 Mainstream Vouchers $1.92M
97.024 Emergency Food and Shelter National Board Program $682,638
14.896 Family Self-Sufficiency Program $640,763
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $617,488
14.191 Multifamily Housing Service Coordinators $351,213
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $181,909
16.034 Coronavirus Emergency Supplemental Funding Program $125,837
17.259 Wia Youth Activities $86,247
14.218 Community Development Block Grants/entitlement Grants $3,650