We audited Community Action North Bay’s Continuum of Care Program based on hotline complaints (HC-2016-2275 and HT-2019-1142) and concerns expressed by the San Francisco Office of Community Planning and Development that included matching noncompliance issues. The complaints alleged improper accounting, timekeeping irregularities, unreported program income, and conflicts of interest. Our objective was to determine whether the Community administered its Continuum of Care Program in accordance with U.S. Department of Housing and Urban Development (HUD) requirements.
The complaints and concerns had merit. The Community did not administer its Continuum of Care Program in accordance with HUD requirements. Specifically, it did not maintain documents required to support that (1) it met the matching contribution requirement, (2) its rapid rehousing and permanent supportive housing programs assisted eligible individuals, and (3) program income and expenses were supported and eligible. These conditions occurred because the Community did not implement corrective actions recommended by HUD and its staff lacked the knowledge and skills needed to administer the program. As a result, the Community is at risk of having to repay HUD grant funds totaling $647,827 if it cannot provide supporting documentation related to required matching contributions. It also could not support the eligibility of individuals assisted by its rapid rehousing and permanent supportive housing programs.
We recommend that the Director of HUD’s San Francisco Office of Community Planning and Development require the Community to (1) support that it met the matching contribution requirement or reimburse HUD $577,670 from non-Federal funds, (2) reclassify $28,576 as program income to the specific permanent supportive housing program, and (3) support that $2,687 paid to a board member for legal services was allowed through a HUD-approved waiver or repay HUD from non-Federal funds.