County of Morris

Finding 2020-001: U.S. Department of Urban and Housing Development ? Home Investment Partnerships Program ? Significant Deficiency and Non-Compliance ? Eligibility, Subrecipient Monitoring and Special Tests and Provisions Criteria The HOME Program has income targeting requirements. Only low-income or very low-income persons, as defined in 24 CFR section 92.2, can receive housing assistance (24 CFR section 92.1). Therefore, the participating jurisdiction must determine if each family is income eligible by determining the family's annual income, including all persons in the household, as provided for in 24 CFR section 92.203. Participating jurisdictions must maintain records for each family assisted (24 CFR section 92.508). Also, participating jurisdictions are required to monitor its subrecipients so reasonable assurance is provided that the subrecipient used the subaward for authorized purposes in compliance with Federal statutes, regulations, and the terms and conditions of the subaward. Additionally, the participating jurisdictions are required to ensure that subrecipients expected to be audited as required by CFR part 200, subpart F, met this requirement (2 CFR section 200.331(f)). This verification may be performed as part of the required monitoring under 2 CFR section 200.331(d)(2) to ensure that the subrecipient takes timely and appropriate action on any deficiencies detected though audits. During the period of affordability (i.e., the period for which the non-Federal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than three years for projects containing one to four units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Condition: The Morris County Office of Community Development did not review the eligibility determinations of the persons receiving housing assistance. Also, the County did not monitor its subrecipients or obtain copies of subrecipient audit reports to ensure that the subrecipient took timely and appropriate action on any deficiencies detected in the audits. Finally, the required on-site inspection of HOME assisted rental housing to determine compliance with property standards and verification of the information submitted by the owners no less than every three years for projects containing one to four units were not performed. Cause: Due to the COVID-19 pandemic and reduced staff levels in the Morris County Office of Community Development, the required review of eligibility determinations of persons receiving housing assistance, the monitoring of subrecipients including review of subrecipients? audit reports and the on-site inspections of HOME assisted rental housing were not performed. Effect or Potential Effect: The Morris County Office of Community Development was not in compliance with the HOME Program requirements for required review of eligibility determinations of persons receiving housing assistance, the monitoring of subrecipients including review of subrecipients? audit reports and the on-site inspections of HOME assisted rental housing. Recommendation: It is recommended that adequate policies and procedures are implemented to ensure that the required review of eligibility determinations of persons receiving housing assistance, the monitoring of subrecipients including review of subrecipients? audit reports and the on-site inspections of HOME assisted rental housing are performed by the Morris County Office of Community Development. Management's Response: Adequate policies and procedures will be implemented to ensure that required review of eligibility determinations of persons receiving housing assistance, the monitoring of subrecipients including review of subrecipients? audit reports and the on-site inspections of HOME assisted rental housing are performed by the Morris County Office of Community Development in 2021.

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