The Wayne County Committee on Audit on March 24, 2025 received and filed a performance audit of the county Department of Economic Development's Emergency Rental Assistance (ERA) program that identified multiple control deficiencies tied to third-party administration and database accuracy.

Marcy Corral, auditor general, introduced the audit team and said the engagement examined compliance with grant regulations, program effectiveness and the county's on-site monitoring of subrecipient activities. Will Hamner, audit manager, told commissioners the audit covered the program's inception through closure and used interviews, database reviews and limited discussions with the third-party administrator.

The audit reported that Wayne County established an ERA program funded by a federal award (transcribed in the report as $32,600,000) and contracted a third-party administrator for about $3,200,000. Auditors found numerous weaknesses, including inconsistent processes for validating applicant information; recertification procedures that resulted in some applicants receiving multiple payments while others were not invited to recertify; and database records that did not reconcile to the general ledger. The auditors reported a confirmed database discrepancy of 1,122 applications and said the poor quality of data in the administrator's system made it difficult to determine what happened in many cases.

Crystal Thomas, supervisory auditor, highlighted recertification and payment inconsistencies and warned these could lead to unequal distribution of funds and overpayments. The audit also included a sample-based refugee eligibility finding: from a sample of 10 of 92 refugee participants, three were awarded $19,470 despite not meeting the refugee eligibility requirements based on provided documentation.

County staff, represented in the meeting by Anthony Carver, unit director of economic development, said the ERA program is no longer active and that department leadership had changed since the program was run. Carver said staff reviewed the findings and agreed the report could guide future grant administration. He also named the county's third-party administrator as transcribed in the meeting (recorded as "Guy House" in some remarks and as Guidehouse elsewhere in the record).

Commissioners pressed auditors on dollar impact and next steps. Will Hamner said the audit's sample limits complete quantification of total loss and that larger impacts are possible but would require 100% testing. Staff said roughly $21 million was disbursed for rental assistance to about 4,915 households across 41 communities, with specific subcontractor payments noted (for example, $672,242 to Samaritas and about $800,000 to Lakeshore Legal). Two communities, Sumter Township and Woodhaven, were identified as not receiving any ERA funding.

On legal recourse and recoupment for erroneous payments, county staff said they would consult county counsel to determine whether the county can pursue recovery from the third-party administrator or affected parties and pledged a follow-up.

The audit included 12 recommendations (grouped into four issues) to strengthen oversight of third-party administrators, improve validation and approval procedures, reconcile database records to financials, and require documented secondary reviews by county officials prior to final approvals. Auditors noted management agreed with all recommendations.

After questions and discussion about audit clauses in contracts, capacity to administer similar programs in-house, and the effect of federal rules that permit some self-attestation of eligibility, Commissioner Wilson moved to receive and file the report; the motion was supported and carried.

The committee did not request a corrective action plan within 30 days because the ERA program is no longer active, but auditors and staff said the report's recommendations should be applied to future programs that the county may delegate to third-party administrators.

Next steps recorded in the meeting: staff will follow up with county counsel on recoupment/legal options and supply commissioners with further information about communities served and outstanding discrepancies.