THE OPEN DOOR NETWORK

Continuum of Care, U.S. Department of Housing and Urban Development Federal Assistance Listing #14.267; Contract No. CA1126L9D042209, CA1126L9D042310, CA0869L9D042311, CA0869L9D042412, CA2041D9D042201, CA2041D9D042302, CA1517L9D042308. Condition: Evaluation of reasonable rents lacked supporting documentation and research of comparable housing units and the method thereof were not maintained on record. Additionally, two of five rental assistance payment amounts were determined to be above HUD-determined fair market rents. Lastly, two out of five tenants did not have leases for longer than one year. Criteria: In compliance with Title 24 CFR Subpart D Part §578.49 Leasing (b): (1) Leasing structures. When grants are used to pay rent for all or part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. (2) Leasing individual units. When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents. Additionally, under 24 CFR 578.51(l)(1), for projectbased, sponsor-based, or tenant-based rental assistance, program participants must enter into a lease agreement for a term of at least one year, which is terminable for cause. The leases must be automatically renewable upon expiration for terms that are a minimum of one month long, except on prior notice by either party. Cause: The error stems from the lack of internal controls over retention of supporting documentation. Additionally, the misinterpretation of program compliance requirements resulted in payments in excess of HUD-determined fair market rents and leases executed for less than one year. Effect: The auditor was unable to verify the information obtained to compare housing units in the nearby areas and of similar condition and features. Failure to retain proof of research performed casts doubts on the Organization’s vetting process and procedures to determine reasonable rental assistance. This could result in a loss of funding. Additionally, rental assistance payments were paid despite being in excess of HUD-determined fair market rents. Failure to comply with fair market rent rules could result in an abuse from landlords taking advantage of program funding if rents are intentionally inflated due to the credible nature of federal assistance programs. This could result in a misuse of federal funds which could impact the Organization’s eligibility for future grant funding. Failure to have participants enter into leases in compliance with program requirements may result in participants not receiving the appropriate housing assistance in which they are entitled to. Recommendation: Management should implement controls and procedures for maintaining supporting documentation for all compliance requirements including research on comparable housing units. Additionally, while the Organization has incorporated a procedure during the application process to determine if proposed rental assistance amounts are within HUD-determined fair market value, the Organization bypassed those limits and thereby circumvented its own controls. Management should adhere to set limits on rental assistance and implement controls to prevent aforementioned violations. Finally, management should ensure all leases are executed for longer than one year.

Congressional Directives, U.S Department of Health and Human Services, Federal Assistance Listing #93.493; Contract No. 90XP0658-01-00 Condition: The amount of expenditures covered by the report period were inaccurately reported to the federal granting agency. Criteria: In compliance with Title 24 CFR Subpart D Post Federal Award Requirements §200.302 Financial management (b): The financial management system must provide for (2) Accurate, current, and complete disclosure of the financial results of each Federal award program in accordance with the reporting requirements set forth in SS 200.328 and 200.329.” Cause: The error stems from a clerical oversight related to evaluating the amount of expenditures at the wrong date, as the transactions in the final month of the reporting period had not been closed out by the Organization at the time the report was prepared. Effect: The Organization failed to report the actual amount of expenditures in accordance with the program requirements, resulting in an understatement of $85,195 on the report. Failure to submit accurate funding and financial data could result in loss of future funding. Recommendation: Management should perform an internal review over inputs into federal financial reports before they’re submitted, to verify that inputs are accurate and cover the appropriate reporting period.

Continuum of Care, U.S. Department of Housing and Urban Development Federal Assistance Listing #14.267; Contract No. CA1126L9D042209, CA1126L9D042310,CA0869L9D042311, CA2041D9D042100, CA2041D9D042201, CA1517L9D042207, CA1200L9D042209 Condition: Evaluation of reasonable rents lacked supporting documentation and research of comparable housing units and the method thereof were not maintained on record. Additionally, three of six rental assistance payment amounts were determined to be above HUD-determined fair market rents. Criteria: In compliance with Title 24 CFR Subpart D Part §578.49 “Leasing (b): (1) Leasing structures. When grants are used to pay rent for all or part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. (2) Leasing individual units. When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” Cause: The error stems from the lack of internal controls over retention of supporting documentation. Additionally, the misinterpretation of program compliance requirements resulted in payments in excess of HUD-determined fair market rents. Effect: The auditor was unable to verify the information obtained to compare housing units in the nearby areas and of similar condition and features. Failure to retain proof of research performed casts doubt on the Organization's vetting process and procedures to determine reasonable rental assistance. This could result in a loss of funding. Additionally, rental assistance payments were paid despite being in excess of HUD determined fair market rents. Failure to comply with fair market rent rules could result in an abuse from landlords taking advantage of program funding if rents are intentionally inflated due to the credible nature of federal assistance programs. This could result in a misuse of federal funds which could impact the Organization's eligibility for future grant funding. Recommendation: Management should implement controls and procedures for maintaining supporting documentation for all compliance requirements including research on comparable housing units. Additionally, while the Organization has incorporated a procedure during the application process to determine if proposed rental assistance amounts are within HUD-determined fair market value, the Organization bypassed those limits and thereby circumvented its own controls. Management should adhere to set limits on rental assistance and implement controls to prevent aforementioned violations.

Continuum of Care Program, U.S. Department of Housing and Urban Development Federal Assistance Listing #14.267; Contract No. CA1126L9D042209, CA1126L9D042310, CA0869L9D042311, CA2041D9D042100, CA2041D9D042201, CA1517L9D042207, CA1200L9D042209 Condition: Matching requirements were not met for five of the seven grantor's numbers under the program. Criteria: In compliance with Title 24 CFR Subpart F—Program Requirements §578.73 Matching requirements. (a) In general. The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of funds or in-kind contributions from other sources. For Continuum of Care geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-bygrant basis. Recipients that are UFAs or are the sole recipient for their Continuum, may provide match on a Continuum-wide basis. Cash match must be used for the costs of activities that are eligible under subpart D of this part, except that HPCs may use such match for the costs of activities that are eligible under §578.71.” Cause: The error stems from the lack of understanding of matching requirements and methods including allowable usage of other grant funds and application of funding towards specific program expenditures. Effect: The Organization failed to produce funds in accordance with the program requirements. Failure to match funding could result in loss of future funding. Recommendation: Management should obtain greater understanding of matching rules and requirements to adequately track and expend matching funds. Management should implement controls and procedures for maintaining supporting documentation for all matched expenditures and sources of match funding.

Emergency Solutions Grant Program, U.S. Department of Housing and Urban Development Federal Assistance Listing #14.231; Contract No. 015-2024, 144-2022, 221-2023, 279-2023, 641-2023, 518-2022, 2022-243, 2023-293, 2023-125, 2023-292, 2023-288, 2022-238 Condition: The Organization failed to fully match funding for ten of the twelve grantor's numbers under the program. Out of a total required match of $606,436, only a portion of matched funds were made in the amount of $370,745, resulting in an unfunded match of $235,691. Criteria: In compliance with Title 24 CFR Subpart C—Awards and Use of Funds §576.201 “Matching requirement. (a) The recipient must make matching contributions to supplement the recipient's Emergency Solution Grant (ESG) program in an amount that equals the recipient's fiscal year grant for ESG. This amount may include contributions to any project under the recipient's ESG program, including any subrecipient's ESG project, if the requirements in this section are met.” Cause: The error stems from the lack of understanding of matching requirements and methods including allowable usage of other grant funds and application of funding towards specific program expenditures. Effect: The Organization failed to match funds in accordance with the program requirements. Failure to match funding could result in loss of future funding. Recommendation: Management should obtain greater understanding of matching rules and requirements to adequately track and expend matching funds. Management should implement controls and procedures for maintaining supporting documentation for all matched expenditures and sources of match funding.