Finding Text
2023‐002 — Controls over Compliance –Rent Reasonableness – (Significant Deficiency)
Federal Program Information:
Funding Agency: Housing and Urban Development
Title: Continuum of Care
Assistance Listing Number: 14.267
Compliance Requirement: Special Tests and Provisions
Award Year: July 1, 2022 to June 30, 2023
Condition: During our audit, we noted that Barrett Foundation had one of three tenants sampled who did not have
evidence that the rent reasonableness form was reviewed or approved.
Criteria: Barrett Foundation has a policy that its process over the rent reasonableness requirement is for one
employee to fill out a rent reasonableness form and the supervisor to review and approve it before any rent payments
are made on behalf of the client.
Effect: Barrett Foundation did not have evidence that it followed its policy over the rent reasonableness requirement.
Questioned Costs: None
Cause: Barrett Foundation did not file the signed version of the rent reasonableness form and only had the unsigned
version to show for the audit. This was due to turnover and certain documents not being filed correctly.
Auditors’ Recommendation: We recommend that Barrett Foundation ensure that all signed documents are scanned
into the Foundation’s server to show evidence that all policies and procedures were followed.
Management’s Response: In FY23, Barrett Foundation experienced significant staffing shortages which resulted in
Rent Reasonableness forms not being reviewed or signed. During FY24, Barrett Foundation audited all case files to
address incomplete documentation. We also updated our standard operating procedures to indicate that rent
reasonableness forms are completed annually as well as when a participant enters the programs, moves to a different
unit, if there is a rent increase and that supervisors review and sign the form. Additionally, supervisors will begin
conducting monthly random audits of client files to ensure that all required documentation is completed.