Finding 638035 (2022-001)

Finding: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Eligibility Federal Program: COVID-19 - Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: Department of Treasury Criteria or specific requirement: In accordance with the Consolidated Appropriations Act, 2021, sections 501(c)(2)(C)(ii) of the Act grantees should establish and adhere to reasonable policies for evaluating household applications within Treasury?s framework providing for the use of self-attestation, categorical eligibility, and fact-specific proxies in qualifying circumstances. Condition: Required eligibility determinations were found to be incomplete (including obtaining required documentation/verification). Eligibility could not be determined for select individual program recipients as the required documentation was missing for the files to determine eligibility. Cause: Internal protocols over eligibility determinations were not adhered to, to ensure that individual program recipients were eligible for the program. Effect or Potential Effect: Amounts provided to or on behalf of eligible participants are in question due to missing documentation to base eligibility determinations. As such, certain eligibility costs provided to participants have been deemed questioned costs. Questioned Costs: $56,235. Questioned costs were determined by reviewing the amounts provided to participants that have been deemed ineligible due to missing documentation to base an eligibility determination. Context: During our testing, the City made us aware of a complaint provided through the City's Integrity Line. As a result of the complaint, an internal investigation was conducted, where certain participant files were missing documentation to base an eligibility determination. Identification as a Repeat Finding: N/A Recommendation: Management should review existing procedures to ensure that required eligibility determinations are consistently made (including obtaining required documentation/verification) and verified by supervisory staff prior to program participants receiving financial assistance/benefits. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.