EIN: 581772685
UEI: D5NVBYGBAWN7
Audited by: Corliss & Solomon, PLLC
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 25, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 25, 2026 (27 days from today).
What is a management decision? →During the testing of tenant files, we discovered one miscalculation on the income calculation sheet: 1 – Incorrect Rental Calculation on Participant #20 (Criteria 1) Cause: WNCAP personnel miscalculated Participant #20's income, which resulted in the incorrect amount of support provided. Effect: Some individuals received the incorrect amount of support. Questioned Costs: Undeterminable Context: During the year, 74 unique clients were served. We sampled 25 tenant files for multiple compliance requirements. Recommendation:. Management should also ensure that eligibility for assistance is properly calculated. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Show full finding ▾Hide full finding ▴2025-001 – 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, we discovered one miscalculation on the income calculation sheet: 1 – Incorrect Rental Calculation on Participant #20 (Criteria 1) Cause: WNCAP personnel miscalculated Participant #20's income, which resulted in the incorrect amount of support provided. Effect: Some individuals received the incorrect amount of support. Questioned Costs: Undeterminable Context: During the year, 74 unique clients were served. We sampled 25 tenant files for multiple compliance requirements. Recommendation:. Management should also ensure that eligibility for assistance is properly calculated. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2025-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on Client #20 Corrective Action: Section 1 RE: Incorrect Rental Calculation: The incorrect calculation referenced in this finding was due to a typo, which resulted in an incorrect payment. To catch simple human errors such as this in the future, management will update the rent calculation worksheet to include reminders to double check data entry in fields that are easy to transpose. Management will also update the recertification process to add the following additional steps: The Data Technician will also review the rent calculation worksheet and the supporting documentation to ensure the amounts in the supporting document(s) match the entry in the worksheet; the Housing Coordinator will conduct a randomized audit of at least two rent calculation worksheets each month. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2023-24 audit: 2023-24 Total Deficient Eligibility Records: 2024-25 Total Deficient Eligibility Records: WNCAP expects to see continued improvement in subsequent audits.
2024-001
FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on Participant #10 (Criteria 1) 1 – Incorrect amount of support provided to Participant #10, and (Criteria 1) 1 – Missing documentation of lease contract for Participant #6 (Criteria 2) Cause: WNCAP personnel miscalculated Participant #10's income, which resulted in the incorrect amount of support being provided. The landlord for Participant #6 refused to provide the lease agreement. Effect: Compliance with eligibility could not be determined for some sampled tenants. Therefore, some ineligible individuals may have received assistance under the program. Some individuals received the incorrect amount of support. Questioned Costs: Undeterminable Context: During the year, 85 unique clients were served. We sampled 20 tenant files for multiple compliance requirements. Identification of a Repeat Finding: Criteria 2 is a repeat finding from the immediate previous audit, 2023-001. 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 should also ensure that eligibility for assistance is properly calculated. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-001 – 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: 1 – Incorrect Rental Calculation on Participant #10 (Criteria 1) 1 – Incorrect amount of support provided to Participant #10, and (Criteria 1) 1 – Missing documentation of lease contract for Participant #6 (Criteria 2) Cause: WNCAP personnel miscalculated Participant #10's income, which resulted in the incorrect amount of support being provided. The landlord for Participant #6 refused to provide the lease agreement. Effect: Compliance with eligibility could not be determined for some sampled tenants. Therefore, some ineligible individuals may have received assistance under the program. Some individuals received the incorrect amount of support. Questioned Costs: Undeterminable Context: During the year, 85 unique clients were served. We sampled 20 tenant files for multiple compliance requirements. Identification of a Repeat Finding: Criteria 2 is a repeat finding from the immediate previous audit, 2023-001. 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 should also ensure that eligibility for assistance is properly calculated. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2024-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on client DNSE 1 – Incorrect amount of support provided to DNSE, and 1 – Missing documentation of lease contract for client AGFA Corrective Action: Section 1 RE: Incorrect Rental Calculation & Incorrect amount of support paid to landlord: WNCAP will continue utilizing the eligibility checklist implemented with the 2022 corrective action plan, as it has resulted in the significant reduction of errors, as evidenced by the continued improvement in comparison to previous audits. The incorrect calculation referenced in this finding was due to a typo, which resulted in an overpayment. To catch simple human errors such as this in the future, management will update the rent calculation worksheet to include reminders to double check data entry in fields that are easy to transpose. Management will also update the recertification process to add the following additional steps: The Data Technician will also review the rent calculation worksheet and the supporting documentation to ensure the amounts in the supporting document(s) match the entry in the worksheet; the Housing Coordinator will conduct a randomized audit of at least two rent calculation worksheets each month. Section 2 RE: Missing documentation of lease contract. WNCAP management will confer with state grant monitors to create and implement a zero-tolerance policy that abates payments immediately if a landlord or client does not provide the documents necessary for recertification in a timely manner. Unfortunately, this will likely result in some evictions and may jeopardize WNCAP’s ability to recruit landlords in a highly competitive market, but there is no guidance on any alternatives that would preserve housing stability as long as possible while still being considered compliant. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2022-23 audit: 2022-23 Total Deficient Eligibility Records: 8 2023-24 Total Deficient Eligibility Records: 3 WNCAP expects to see continued improvement in subsequent audits.
2023-001
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 4 -- Missing documentation of landlord participation agreements, 1 -- Missing documentation of landlord participation agreements, due to incomplete record of transfer from WNCHS, 1 -- Missing documentation of lease contract, 2 – Missing documentation of housing assistance form. 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, 83 unique clients were served. We sampled 20 tenant files for multiple compliance requirements. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2022-002. 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.
Show full finding ▾Hide full finding ▴2023-001 – 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: 4 -- Missing documentation of landlord participation agreements, 1 -- Missing documentation of landlord participation agreements, due to incomplete record of transfer from WNCHS, 1 -- Missing documentation of lease contract, 2 – Missing documentation of housing assistance form. 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, 83 unique clients were served. We sampled 20 tenant files for multiple compliance requirements. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2022-002. 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.
2023-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 4 -- Missing documentation of landlord participation agreements, 1 -- Missing documentation of landlord participation agreements, due to incomplete record of transfer from WNCHS, 1 -- Missing documentation of lease contract, 2 -- Missing documentation of housing assistance form. Corrective Action: As outlined in previous year’s corrective action plan, WNCAP has implemented an eligibility checklist to ensure that client records are complete. The Housing Coordinator has shared the review checklist with frontline employees so they can use it as reference when completing intakes and recertifications, and she regularly reviews client files to ensure the records are complete. While the checklist was implemented in the first quarter of 2023, some of the records were created prior to implementation. Going forward, all records for the following audit period will have been created after implementation of the review checklist. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2021-22 audit: 2021-22 Total Deficient Eligibility Records: 30 2022-23 Total Deficient Eligibility Records: 8 WNCAP expects to see continued improvement in subsequent audits.
2022-002
During testing of tenant files, there were 1 instance where inspection documentation or HQS documentation was missing. Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled. Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards. Questioned Cost: None Context: A sample of 20 tenant files were selected from a population of 83 tenants. The test found 1 exceptions, as noted above. Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2022-004. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Show full finding ▾Hide full finding ▴2023-002 Housing Quality Standards Significant Deficiency Criteria: All housing that involves acquisition, rehabilitation, conversion, lease, repair of facilities, new construction, project or tenant-based rental assistance, and operating costs must meet various housing quality standards listed in 24 CFR sections 574.310(b)(1)-(2). Condition: During testing of tenant files, there were 1 instance where inspection documentation or HQS documentation was missing. Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled. Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards. Questioned Cost: None Context: A sample of 20 tenant files were selected from a population of 83 tenants. The test found 1 exceptions, as noted above. Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2022-004. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
2023-002 Housing Quality Standards Condition: During testing of tenant files, there were 1 instance where inspection documentation or HQS documentation was missing. Corrective Action: The Housing Coordinator is completing the updated trainings that the HOPWA program published recently in hudexchange.info. An eligibility checklist has been implemented as well, as noted in the previous year’s single audit, which includes housing inspection or HQS documentation as one of the compliance items. In addition, to ensure that all housing staff understands the eligibility requirements, the Housing Coordinator has shared the review checklist with frontline employees, and regularly reviews client files to ensure the records are complete. Lastly, evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2021-22 audit: 2021-22 Total Deficient Inspection/HQS Records: 5 2022-23 Total Deficient Inspection/HQS Records: 1 WNCAP expects to see continued improvement in subsequent audits.
2022-004
FAC accepted this audit on October 27, 2023 — management decision was due April 27, 2024.
The WNCAP Single Audit was not submitted to the Federal Audit Clearinghouse within the prescribed period. Cause: Turnover in key finance positions along with COVID caused delays in the completion of the prior year audit which in turn affected the completion and timely filing of the current year Single Audit. Effect: Management was not in compliance with the requirement to timely submit the Single Audit to the FAC. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-002. Recommendation: Management should implement procedures ensure that the financial statements are submitted to the FAC in accordance with filing requirements. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Show full finding ▾Hide full finding ▴2022-001 Single Audit Submission Significant Deficiency Criteria: The Federal Office of Management and Budget (OMB) Circular 2 CFR 200.512(a) requires that a non-profit organization expending $750,000 or more in total cumulative Federal funds must have a Single Audit performed in accordance with the Single Audit Act. This audit reporting package must normally be submitted and received by the Federal Audit Clearinghouse (FAC) the earlier of 30 days after the report date or nine months after the fiscal year end. The due date for submission of WNCAP’s June 30, 2022, audit to the Clearinghouse was March 31, 2023. Condition: The WNCAP Single Audit was not submitted to the Federal Audit Clearinghouse within the prescribed period. Cause: Turnover in key finance positions along with COVID caused delays in the completion of the prior year audit which in turn affected the completion and timely filing of the current year Single Audit. Effect: Management was not in compliance with the requirement to timely submit the Single Audit to the FAC. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-002. Recommendation: Management should implement procedures ensure that the financial statements are submitted to the FAC in accordance with filing requirements. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Condition: The WNCAP Single Audit was not submitted to the Federal Audit Clearinghouse within the prescribed period. Corrective Action: The key position of Director of Finance was filled in October 2022, and will remain appropriately staffed going forward. The main cause for this delay was the delay of the previous Single Audit, since it extended into this fiscal year’s timeline. The Director of Finance was able to complete the SEFSA for this audit in a timely manner, and the audit progressed at a reasonable pace. Management will continue to refine internal processes for efficiency; and WNCAP is on track to submit the next Single Audit (FY 2022-23) by the standard deadline of March 31, 2024. In addition, management created a risk assessment policy and procedure to be initiated any time there is turnover in key personnel who play a role in the finance-related activities of the organization. The process includes the following steps: naming an assessor/monitor to lead the effort, who must be the staff member at the highest level of financial responsibility; creation of a monitoring plan that identifies risks, their potential impacts, the actionable steps to mitigate said impacts, and assigns actionable steps to specific staff. The assessor/monitor decides the duration of the monitoring period, and is tasked with routinely meeting with responsible staff to ensure mitigation activities are implemented, and update the monitoring plan as needed. One of the potential impacts named in the policy is “past-due submission of the Single Audit into the FAC”.
2021-002
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.
Show full finding ▾Hide full finding ▴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.
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.
2021-003
Disbursements were not supported by complete and verifiable evidence. The following errors were noted: 1-- Check amount did not agree with invoice amount for mileage reimbursement, 1 -- Missing or incomplete documentation 1 -- Check request was not signed by supervisor 1 – Check did not clear the bank within a reasonable time Cause: The shift to remote work and varying levels of technical knowledge among staff on digital recordkeeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten. Effect: Disbursements might have been made for unallowable activities or in violation of cost principles. Questioned Costs: None Context: 40 disbursements were reviewed out of a population of 1102. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-004. Recommendation: We recommend that management improve internal controls over disbursements and supporting documentation to ensure that all necessary information is included in the client files. We also recommend that reconciliations be reviewed to determine that all checks have cleared and that there is follow-up on any that have not cleared within a reasonable time. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Show full finding ▾Hide full finding ▴2022-003 – Unsupported Expenses Significant Deficiency (A) Activities Allowed or Unallowed (B) Allowable Costs/Cost Principles Criteria: HOPWA funds may be used to assist all forms of housing designed to prevent homelessness. Disbursements should be supported by verifiable audit evidence. Condition: Disbursements were not supported by complete and verifiable evidence. The following errors were noted: 1-- Check amount did not agree with invoice amount for mileage reimbursement, 1 -- Missing or incomplete documentation 1 -- Check request was not signed by supervisor 1 – Check did not clear the bank within a reasonable time Cause: The shift to remote work and varying levels of technical knowledge among staff on digital recordkeeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten. Effect: Disbursements might have been made for unallowable activities or in violation of cost principles. Questioned Costs: None Context: 40 disbursements were reviewed out of a population of 1102. Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2021-004. Recommendation: We recommend that management improve internal controls over disbursements and supporting documentation to ensure that all necessary information is included in the client files. We also recommend that reconciliations be reviewed to determine that all checks have cleared and that there is follow-up on any that have not cleared within a reasonable time. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Condition: Disbursements were not supported by complete and verifiable evidence. The following errors were noted: 1 – Check amount did not agree with invoice amount for mileage reimbursement. 1 – Missing or incomplete documentation 1 – Check request was not signed by supervisor 1 – Check did not clear the bank within a reasonable time 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: Management created a review tool checklist of all required forms for the frontline staff to use as reference, for the Housing Coordinator to review assistance requests and client charts; and for leadership to conduct randomized internal audits; 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. The goal is for the process to be completed, and new forms implemented, by November 1st, 2023. In addition, management has implemented review of outstanding checks on a monthly basis as part of the reconciliation process. This has already helped management identify landlords who do not deposit checks in a timely manner, which results in outreach from the Housing Coordinator to confirm they received the check, and to request that they deposit it ASAP. Lastly, the Director of Finance has streamlined the payment process by implementing the use of direct deposits to make rent payments, which many landlords have already enrolled in. Management will continue encouraging enrollment in the direct deposit payment model, and will gradually phase out rent payments by check. The results of the improved controls, and the direct deposit rent payment model, will be reflected in the FY 2022-23 Single Audit. As was explained in the previous corrective action (Finding 2022-002), some of these improvements were implemented in the first quarter of calendar year 2023.
2021-004
During testing of tenant files, there were 5 instances where inspection documentation or HQS documentation was missing. Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled. Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards. Questioned Cost: None Context: A sample of 22 tenant files were selected from a population of 113 tenants. The test found 5 exceptions, as noted above. Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan. 2022-004 Housing Quality Standards Significant Deficiency Criteria: All housing that involves acquisition, rehabilitation, conversion, lease, repair of facilities, new construction, project or tenant-based rental assistance, and operating costs must meet various housing quality standards listed in 24 CFR sections 574.310(b)(1)-(2). Condition: During testing of tenant files, there were 5 instances where inspection documentation or HQS documentation was missing. Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled. Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards. Questioned Cost: None Context: A sample of 22 tenant files were selected from a population of 113 tenants. The test found 5 exceptions, as noted above. Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Show full finding ▾Hide full finding ▴2022-004 Housing Quality Standards Significant Deficiency Criteria: All housing that involves acquisition, rehabilitation, conversion, lease, repair of facilities, new construction, project or tenant-based rental assistance, and operating costs must meet various housing quality standards listed in 24 CFR sections 574.310(b)(1)-(2). Condition: During testing of tenant files, there were 5 instances where inspection documentation or HQS documentation was missing. Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled. Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards. Questioned Cost: None Context: A sample of 22 tenant files were selected from a population of 113 tenants. The test found 5 exceptions, as noted above. Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan. 2022-004 Housing Quality Standards Significant Deficiency Criteria: All housing that involves acquisition, rehabilitation, conversion, lease, repair of facilities, new construction, project or tenant-based rental assistance, and operating costs must meet various housing quality standards listed in 24 CFR sections 574.310(b)(1)-(2). Condition: During testing of tenant files, there were 5 instances where inspection documentation or HQS documentation was missing. Cause: During this period of switching to remote work due to COVID and incorporating electronic files, documentation was frequently misfiled. Effect: The Program was not in compliance with federal regulations regarding documentation of housing quality standards. Questioned Cost: None Context: A sample of 22 tenant files were selected from a population of 113 tenants. The test found 5 exceptions, as noted above. Recommendation: We recommend that the organization strengthen its internal control procedures related to housing quality standards and inspections and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files. Management’s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Condition: During testing of tenant files, there were 5 instances where inspection documentation or HQS documentation was missing. Corrective Action: Management has established the proposed controls included in the Recommendations outlined in the Federal Awards Findings and Questioned Costs document: Management created a review tool checklist of all required forms for the frontline staff to use as reference, for the Housing Coordinator to review assistance requests and client charts; and for leadership to conduct randomized internal audits; 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. 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.
FAC accepted this audit on March 19, 2023 — management decision was due September 19, 2023.
The WNCAP Single Audit was not submitted to the Federal Audit Clearinghouse within the prescribed period. Cause: Turnover in key finance positions along with COVID caused delays in the determination of the need for a Single Audit and in the location of required documentation. Effect: Management was not in compliance with the requirement to timely submit the Single Audit to the FAC. Recommendation: Management should implement procedures for determining when a Single Audit is required in order to ensure that the financial statements are submitted to the FAC in accordance with filing requirements. Management?s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Show full finding ▾Hide full finding ▴2021-002 Single Audit Submission Significant Deficiency Criteria: The Federal Office of Management and Budget (OMB) Circular 2 CFR 200.512(a) requires that a non-profit organization expending $750,000 or more in total cumulative Federal funds must have a Single Audit performed in accordance with the Single Audit Act. This audit reporting package must normally be submitted and received by the Federal Audit Clearinghouse (FAC) the earlier of 30 days after the report date or nine months after the fiscal year end. With the additional six-month COVID extension granted by OMB, the due date for submission of WNCAP?s June 30, 2021, audit to the Clearinghouse was September 30, 2022. Condition: The WNCAP Single Audit was not submitted to the Federal Audit Clearinghouse within the prescribed period. Cause: Turnover in key finance positions along with COVID caused delays in the determination of the need for a Single Audit and in the location of required documentation. Effect: Management was not in compliance with the requirement to timely submit the Single Audit to the FAC. Recommendation: Management should implement procedures for determining when a Single Audit is required in order to ensure that the financial statements are submitted to the FAC in accordance with filing requirements. Management?s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Finding 2021-002 Condition: The WNCAP Single Audit was not submitted to the Federal Audit Clearinghouse within the prescribed period. Corrective Action: The key position of Director of Finance has been filled, and will remain appropriately staffed going forward. The Director of Finance will maintain a cumulative record of total federal grant expenses to promptly determine if a Single Audit is necessary. The Director of Finance will also maintain required documentation readily available.
During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 7 -- Missing or inadequate proof of residency, 4 -- Missing documentation of medical diagnosis, 9 -- Missing documentation of current income or third-party verification of income. 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, 131 unique clients were served. We sampled 26 tenant files for multiple compliance requirements. 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.
Show full finding ▾Hide full finding ▴2021-003 ? 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: 7 -- Missing or inadequate proof of residency, 4 -- Missing documentation of medical diagnosis, 9 -- Missing documentation of current income or third-party verification of income. 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, 131 unique clients were served. We sampled 26 tenant files for multiple compliance requirements. 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.
Finding 2021-003 Condition: During the testing of tenant files, certain eligibility deficiencies were noted as summarized below: 7 -- Missing or inadequate proof of residency, 4 -- Missing documentation of medical diagnosis, 9 -- Missing documentation of current income or third-party verification of income. Corrective Action: Management is establishing new controls to ensure that eligibility documentation is complete for all service recipients. These controls include: review tool check list of all required forms; consolidation of forms that serve similar purposes; clarification of which compliance element is being satisfied by each form; re-training frontline staff on the rationale and importance of each form; and additional layer of review by Data Specialist in charge of maintaining recordkeeping systems.
Disbursements were not supported by complete and verifiable evidence. The following errors were noted: 7 - Check request was missing supervisor signature and/or approval 6 - Missing or incomplete documentation 5 -- Payments for utilities were not supported with copies of invoices 1 - Documentation was for rent, payment was for utilities (electric) 1 - Payment was included in both TBRA and PHP categories. 6 - Checks not clearing the bank were not detected within a reasonable time Cause: The shift to remote work and varying levels of technical knowledge among staff on digital recordkeeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten. Effect: Disbursements might have been made for unallowable activities or in violation of cost principles. Questioned Costs: Two checks to eligible recipients totaling $1,329.48 had not cleared the bank and were not refunded to the State within a reasonable time. Context: 54 disbursements were reviewed out of a population of 599. Recommendation: We recommend that management improve internal controls over disbursements and supporting documentation to ensure that all necessary information is included in the client files. We also recommend that reconciliations be reviewed to determine that all checks have cleared and that there is follow-up on any that have not cleared within a reasonable time. Management?s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Show full finding ▾Hide full finding ▴2021-004 ? Unsupported Expenses Significant Deficiency (A) Activities Allowed or Unallowed (B) Allowable Costs/Cost Principles Criteria: HOPWA funds may be used to assist all forms of housing designed to prevent homelessness. Disbursements should be supported by verifiable audit evidence. Condition: Disbursements were not supported by complete and verifiable evidence. The following errors were noted: 7 - Check request was missing supervisor signature and/or approval 6 - Missing or incomplete documentation 5 -- Payments for utilities were not supported with copies of invoices 1 - Documentation was for rent, payment was for utilities (electric) 1 - Payment was included in both TBRA and PHP categories. 6 - Checks not clearing the bank were not detected within a reasonable time Cause: The shift to remote work and varying levels of technical knowledge among staff on digital recordkeeping as a result of the COVID crisis resulted in inconsistencies in saving data and caused some files to be overwritten. Effect: Disbursements might have been made for unallowable activities or in violation of cost principles. Questioned Costs: Two checks to eligible recipients totaling $1,329.48 had not cleared the bank and were not refunded to the State within a reasonable time. Context: 54 disbursements were reviewed out of a population of 599. Recommendation: We recommend that management improve internal controls over disbursements and supporting documentation to ensure that all necessary information is included in the client files. We also recommend that reconciliations be reviewed to determine that all checks have cleared and that there is follow-up on any that have not cleared within a reasonable time. Management?s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Finding 2021-004 Condition: Disbursements were not supported by complete and verifiable evidence. The following errors were noted: 7 - Check request was missing supervisor signature and/or approval 6 - Missing or incomplete documentation 5 -- Payments for utilities were not supported with copies of invoices 1 - Documentation was for rent, payment was for utilities (electric) 1 - Payment was included in both TBRA and PHP categories. 6 - Checks not clearing the bank were not detected within a reasonable time Corrective Action: Management is establishing new controls to ensure that supporting documentation for expenses is complete for all disbursements. These controls include: additional layer of review by Director of Finance to avoid duplication of expenses in more than one service category; periodic review of outstanding checks that are 45< days old; review tool checklist for all required supporting documents for each request for assistance; clarification of which requirement is being satisfied by each form; re-training frontline staff on the rationale and importance of each form; and additional layer of review for completion by Data Specialist in charge of maintaining recordkeeping systems.
During testing of tenant files, there were 12 instances where rent reasonableness testing documentation was missing. Cause: Management at the time mistakenly believed that documenting FMR (Fair Market Rent) satisfied this requirement. Effect: The Program was not in compliance with federal regulations regarding documentation of reasonable rent. Questioned Cost: Undeterminable Context: A sample of 26 tenant files were selected from a population of 131 tenants. The test found 12 exceptions, as noted above. Recommendation: We recommend that the organization strengthen its internal control procedures related to rent reasonableness testing and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files. Management?s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Show full finding ▾Hide full finding ▴2021-005 Rent Reasonableness Significant Deficiency Criteria: The rent charged for a unit must be reasonable in relation to rents currently being charged for comparable units in the private unassisted market and must not be in excess of rents currently being charged by the owner for comparable unassisted units. 24 CFR 574.320 Condition: During testing of tenant files, there were 12 instances where rent reasonableness testing documentation was missing. Cause: Management at the time mistakenly believed that documenting FMR (Fair Market Rent) satisfied this requirement. Effect: The Program was not in compliance with federal regulations regarding documentation of reasonable rent. Questioned Cost: Undeterminable Context: A sample of 26 tenant files were selected from a population of 131 tenants. The test found 12 exceptions, as noted above. Recommendation: We recommend that the organization strengthen its internal control procedures related to rent reasonableness testing and documentation. This should include management training in the applicable compliance requirements and more effective communication of the requirements to staff, as well as improved monitoring of tenant files. Management?s View: We agree with this finding and have outlined our response in our Corrective Action Plan.
Finding 2021-005 Condition: During the testing of tenant files, there were 12 instances where the rent reasonableness information was missing. Corrective Action: The Data Specialist will be tasked with reviewing all tenant files to ensure that rent reasonableness calculation has been performed and properly documented. Housing Case Managers will be trained to update rent reasonableness calculation any time a client?s rent increases, or when the tenant moves to a different unit. The program manager will ensure all new placements include rent reasonableness calculation going forward.
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