Finding 850 (2022-002)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2022

Accepted

2023-10-27

Audit: 1622

Organization: Western North Carolina Aids Project, Inc. (NC)

Auditor: Corliss & Solomon PLLC

AI Summary

Core Issue: Incomplete tenant files led to uncertainty about eligibility for housing assistance, risking aid to ineligible individuals.
Impacted Requirements: Missing documentation included release forms, income verification, and housing plans, violating eligibility criteria.
Recommended Follow-Up: Establish stronger internal controls to ensure all necessary documentation is collected and maintained for each tenant.

Finding Text

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.

Corrective Action Plan

Condition: During the testing of tenant files, certain documentation deficiencies 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. Corrective Action: Management has established the proposed controls included in the previous audit, which match the Recommendations outlined in the Federal Awards Findings and Questioned Costs document: created a review tool checklist of all required forms for management to review assistance requests and client charts; updated the training curriculum for Housing Department staff, new frontline staff has been hired and trained to include clarification of compliance elements, the rationale and their importance, and which forms satisfy each one. Management also decided to overhaul all department forms and has begun a review process. WNCAP recognizes that the deficiency appears to persist, but this is due to the corrective actions being implemented in the first quarter of 2023, which is when the final audit report for FY 2020-21 was completed, and which time period is not covered by this audit. After implementation, internal review of client records confirms that they addressed this deficiency, as evidenced by the complete, compliant files. This will be reflected in the next Single Audit for FY 2022-23, and going forward.

Other Findings in this Audit

849 2022-001

Significant Deficiency Repeat
851 2022-003

Significant Deficiency Repeat
852 2022-004

Significant Deficiency
577291 2022-001

Significant Deficiency Repeat
577292 2022-002

Significant Deficiency Repeat
577293 2022-003

Significant Deficiency Repeat
577294 2022-004

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
14.241	Housing Opportunities for Persons with Aids	$785,833
93.917	Hiv Care Formula Grants	$197,823
93.940	Hiv Prevention Activities_health Department Based	$159,113
93.488	National Harm Reduction Technical Assistance and Syringe Services Program (ssp) Monitoring and Evaluation Funding Opportunity	$102,981
93.361	Nursing Research	$54,950