We reviewed the Northlake Homeless Coalition’s Continuum of Care Program (CoC) based on a hotline complaint alleging impropriety in Northlake’s selection of grant award recipients and as part of our annual audit plan. The objective of our review was to determine whether Northlake administered its CoC in accordance with the U.S. Department of Housing and Urban Development’s (HUD) and its own program requirements.
The hotline complaint did not have merit. However, Northlake did not always administer its CoC in accordance with HUD’s and its own requirements, as it did not always (1) monitor its program partners, (2) maintain adequate supporting documentation for disbursements, and (3) follow procurement requirements. In addition, Northlake did not always ensure that its board members (1) executed code-of-conduct and conflict-of-interest forms, (2) met monthly, (3) maintained written documentation of board meetings, and (4) updated its charters annually. This condition occurred because Northlake was not fully aware of requirements and lacked adequate policies and procedures and staff. As a result, Northlake could not provide reasonable assurance to HUD that its program met its purpose or that it followed HUD’s and other requirements, putting more than $2 million in CoC funds allocated to its program partners at risk of mismanagement. In addition, Northlake paid more than $120,000 in questioned costs.
We recommend that the Director of HUD’s New Orleans, LA, Office of Community Planning and Development require Northlake to (1) develop and implement written procedures and take actions to ensure that its program partners better spend more than $2 million, (2) support or repay $128,692, (3) annually monitor its CoC recipients as required, and (4) develop and implement procedures to ensure that its CoC is administered in accordance with HUD’s and its own requirements.
Recommendations
Community Planning and Development
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Status2019-FW-1005-001-AOpenClosed$2,092,545.00Funds Put to Better Use
Recommendations that funds be put to better use estimate funds that could be used more efficiently. For example, recommendations that funds be put to better use could result in reductions in spending, deobligation of funds, or avoidance of unnecessary spending.
Closed on September 28, 2020We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement a HUD-approved written plan and procedures and take actions that will correct and prevent the monitoring deficiencies in the finding, improve program administration effectiveness, and ensure compliance with HUD regulations and its own policies and procedures as required. This plan and written procedures should include controls to ensure that Northlake complies with HUD’s and its own requirements for monitoring recipients annually as well as documenting and maintaining the monitoring results. Implementing this recommendation should ensure that the $2,092,545 in HUD funds, allocated to Northlake’s four partners for program execution, is better used.
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Status2019-FW-1005-001-BOpenClosed$83,658.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on October 29, 2021We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to support $81,013 or repay its program from non-Federal funds for disbursements made without adequate supporting documentation.
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Status2019-FW-1005-001-COpenClosedClosed on August 06, 2020
We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement additional policies and controls and procedures, including but not limited to a disbursement file checklist, to ensure that adequate supporting documentation for disbursement is maintained in the files.
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Status2019-FW-1005-001-DOpenClosed$95,358.00Questioned Costs
Recommendations with questioned costs identify costs: (A) resulting from an alleged violation of a law, regulation, contract, grant, or other document or agreement governing the use of Federal funds; (B) that are not supported by adequate documentation (also known as an unsupported cost); or (C) that appear unnecessary or unreasonable.
Closed on August 31, 2023We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to support $47,679 or repay its program from non-Federal funds for payments made to contractors without written contracts and independent cost estimates.
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Status2019-FW-1005-001-EOpenClosedClosed on August 06, 2020
We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement written policies and procedures, which reflect the required HUD procurement policy standards and ensure compliance with those requirements.
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Status2019-FW-1005-001-FOpenClosedClosed on August 06, 2020
We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to develop and implement written policies and procedures to ensure that its board members execute the proper forms annually, hold and document board meetings, and review its board governance and HMIS governance charters as required.
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Status2019-FW-1005-001-GOpenClosedClosed on October 21, 2020
We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to evaluate its staffing level and determine if it should hire additional staff to carry out program activities.
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Status2019-FW-1005-001-HOpenClosedClosed on October 21, 2020
We recommend that the Director of HUD’s New Orleans Office of Community Planning and Development require Northlake to obtain technical assistance from HUD to evaluate the staff’s training needs and to ensure that responsible staff receives the appropriate training for effective program administration.