TRUMBULL COMMUNITY ACTION PROGRAM

U.S. DEPARTMENT OF THE TREASURY Internal Control Over Compliance – Significant Deficiency – Reporting Finding 2022-005 – ALN 21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM (CAA-HRG) – The financial reports are prepared by the Chief Financial Officer with no review prior to submission. Criteria – Proper internal controls over reporting would include a review of the reporting process by a second individual to ensure the accuracy and validity of the information reported. Condition – There was no evidence of review for any of the financial reports selected for testing. Cause – There was no policy for a review of reports prepared by the Chief Financial Officer. Effect – Without a proper review process in place, inaccuracies in reports could go undetected. Recommendation – A formal review process should be in place to ensure that the reports are properly prepared. Views of Responsible Officials – See Corrective Action Plan

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Significant Deficiency ? Eligibility Finding 2021-003 ? ALN 93.569 COMMUNITY SERVICES BLOCK GRANT (CSBG) ? Several instances were noted in which client eligibility for services could not be determined based on the lack of proper documentation. The Agency?s quality control process was not sufficient to identify that eligibility had not been properly determined and documented. Criteria ? Documentation for an applicant?s eligibility for CSBG services should be sufficient to demonstrate that, where an individualized determination of income was required, staff screened the applicants for income eligibility. While no specific items of documentation are specified by the CSBG Act, documentation must be adequate to support that the Agency reviewed a client?s income and determined them to be eligible for CSBG services. The Agency should have controls over the eligibility process to ensure that the income eligibility process is, in fact, properly documented prior to payment of services. Condition ? For 6 percent of the assistance that was tested under CSBG services, we noted that documentation could not be provided to support whether the client was income eligible. Errors include a lack of proper documentation to support that the income screening was performed and altogether missing file documentation. The Agency?s quality assurance checklist was not included in certain client files; therefore, it appears that controls over the eligibility process are also not operating as designed. Cause ? Due to high demand for services related to utility and mortgage assistance during the COVID-19 pandemic, certain controls and processes that were in place were not always functioning as intended, and adequate support documentation was not always maintained. Agency staffing issues to handle the increase in demand for services may have contributed to these oversights. In addition, the Agency?s quality control procedures were also not followed, and the quality assurance checklist that may have identified some of the noncompliance issues was not performed or maintained in client files. Effect ? Client services may have been provided to applicants that did not meet the income threshold for services under the CSBG requirements, resulting in the Agency being reimbursed for ineligible services. Questioned Costs ? Based on the testing performed and the results of testing, approximately $3,548 (6 percent of the sample totaling $55,954) in questioned costs were identified for grant expenditures that were made on behalf of clients where income eligibility could not be determined. Based on this error rate and the total value of the population of $595,452 in client assistance payments, likely questioned costs relative to these errors totaled $37,756. The questioned and likely questioned costs totaling $41,304 is not material to the federal program. Total Questioned Cost ? $3,548 Total Likely Questioned Cost ? $37,756 Recommendation ? Processes and controls should be established to ensure that proper eligibility testing is performed. Documentation to support that the client is, in fact, eligible should be maintained, and a review of the process by a person who is independent of the determination should be in place prior to payment of any services under the CSBG program. Views of Responsible Officials ? See Corrective Action Plan and Review of Responsible Officials.

U.S. DEPARTMENT OF TREASURY Significant Deficiency ? Eligibility Finding 2021-004 ? ALN 21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM (CAA-HRG) ? We noted an instance in which the documentation to support client income eligibility indicated that the client was over the income guidelines of the program, and assistance under CAA-HRG should not have been provided. The Agency?s quality control process was not sufficient to identify that eligibility had not been properly determined. Criteria ? Documentation for an applicant?s eligibility for CAA-HRG services should be sufficient to demonstrate that, where an individualized determination of income was required, staff screened the applicants for income eligibility. Based on the results of the screening process, the Agency would determine that eligibility has been met or has not been met based on the grant guidelines. Any applicant that does not meet the income guidelines would not quality for services under this grant. The Agency should have controls over the eligibility process to ensure that the income eligibility has been calculated accurately and is properly documented. Condition ? For 3 percent of the assistance that was tested under CAA-HRG services, we noted that the income documentation that was provided indicated that the client was over income and should not have received services under the CAA-HRG grant. Agency controls did not identify that the applicant was over income. Cause ? Due to high demand for services related to utility and mortgage assistance during the COVID-19 pandemic, certain controls and process that were in place were not always functioning as intended. Certain client information was not input into the OCEAN system, and, in certain instances, manual calculations were used for client income eligibility determinations. Errors in the calculations were not detected. Agency staffing issues to handle the increase in demand for services may have contributed to these oversights. In addition, the Agency?s quality control procedures were also not followed, and processes that may have identified some of the noncompliance issues were not performed. Effect ? Client services appear to have been provided to applicants that did not meet the income threshold for services under the CAA-HRG requirements, resulting in the Agency being reimbursed for ineligible services. Questioned Costs ? Based on the testing performed and the results of testing, approximately $4,290 (3 percent of the sample totaling $155,493) in questioned costs were identified for grant expenditures that were made to clients that appeared to be over income. Based on this error rate and the total value of the population of $1,476,341 in client assistance payments, likely questioned costs relative to these errors totaled $40,731. The questioned and likely questioned costs totaling $45,021 are not material to the federal program. Total Questioned Cost ? $4,290 Total Likely Questioned Cost ? $40,731 Recommendation ? Processes and controls should be established to ensure that proper eligibility testing is performed and that any applicants that are determined to be over the income limit are not provided assistance under this grant. Documentation to support the review of income calculations should also be maintained. Views of Responsible Officials ? See Corrective Action Plan and Review of Responsible Officials.