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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.