1. Audit of Utility Payment Assistance Program ABSTRACT
The City has entered into a contract with Interfaith
Ministries of Denton to administer its utility
payment assistance program. Assistance generally
appears to be effectively awarded through this
program. Further clarification of contract terms,
updated procedures, and additional monitoring of
program reports and funds would provide further
assurance that assistance awards are reviewed and
7 s ' approved in accordance with program terms.
Internal Audit Department
City Auditor
Y
Madison Rorschach, CIA, CGAP
AUDIT OF UTILITY PAYMENT Audit Staff
Amber Jackson, MBA, CFE
ASSISTANCE PROGRAM
DENTON
Audit Project#: 020
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Table of Contents
Auditat a Glance...........................................................................................................................................3
Introduction ..................................................................................................................................................4
ManagementResponsibility ........................................................................................................................4
Audit Objectives, Scope, and Methodology................................................................................................4
Findings&Analysis........................................................................................................................................6
Assistance Awards Generally Supported; Some Record Improvements Needed....................................... 6
Awarded Pledges Largely Applied to Utility Accounts Appropriately....................................................... 10
Assistance Restricted to Once a Year; Extreme Hardship Exception Used Frequently ............................ 11
Assistance for Program Employees Need Further Oversight.................................................................... 12
Interfaith Has Begun Addressing Suggested Customer Service Improvements....................................... 14
Public Outreach Efforts are Broadly Effective; but Not Coordinated or Data Informed .......................... 16
Expanding Program Reconciliation Procedures Would Provide Further Assurance................................. 18
Appendix A: Management Response Summary..........................................................................................20
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The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Audit at a Glance
Why we did this Audit: What we Found:
Over the last three fiscal years, the The City has established the Prevent Loss of Utility
City has expended about $0.5 million Service, or PLUS One, Program to assist residents in-
as part of its PLUS One Program. need. The City contracts with Interfaith Ministries, a
These funds must be are disbursed non-profit organization, to administer this Program.
effectively and equitably in order to Our findings are summarized below:
ensure residents are properly
assisted. In addition, this audit was Assistance Application Processing. Interfaith had
included on the City's fiscal year retained adequate documentation to support
2020-21 Audit Plan as approved by awarding assistance to most recipients reviewed;
the City Council. however, inconsistencies were noted and all
documentation prior to Sept. 2018 has been lost. The
City's Customer Service Division generally applied
What we Recommend: pledged awards appropriately.
Recommendations 1, 2,4&9 Finally, some PLUS One assistance was awarded to
Interfaith should update its Interfaith's employees. While all applicable Denton
Assistance Handbook and evaluate its residents should be able to receive assistance,
Client Log. Interfaith and the City should collaborate to ensure
these applications are reviewed and approved
Recommendations 3 &8 appropriately to avoid the appearance of a conflict of
Interfaith should collaborate with the interest.
City on document retention & their
employee assistance approval Customer Service Quality. All surveyed PLUS One
process. Program applicants, including those denied
assistance, stated they believed Interfaith treated
Recommendations 5 & 14 them with respect and dignity. Furthermore,
Customer Service should reconcile Interfaith has begun implementing customer service
Interfaith's monthly bank statements quality control and assurance procedures; results of
& update its refund procedure. these efforts should be reported to the City.
Recommendations 6&7 Program Monitoring & Contract Clarity. The City's
The City should clarify the extreme contract generally limits assistance to residents to
hardship assistance limit exception. once a year; however, it allows those designated as an
Recommendations 10, 11, & 12 extreme hardship to receive additional assistance.
Interfaith should continue training & This exception is not well defined by the contract. In
reporting on customer service addition, restricting assistance may negatively impact
quality. Denton residents with greater need.
Recommendation 13 Moreover, Interfaith provides monthly reports to the
The City should utilize Interfaith's City on applicant demographic information; however,
Monthly Reports to improve Program this information is not regularly analyzed or reviewed
effectiveness. to inform program direction or public outreach
efforts.
CITY YOF m
DENTON
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Introduction
The Internal Audit Department is responsible for providing: (a) an independent appraisal' of City
operations to ensure policies and procedures are in place and complied with, inclusive of
purchasing and contracting; (b) information that is accurate and reliable; (c) assurance that assets
are properly recorded and safeguarded; (d) assurance that risks are identified and minimized; and
(e) assurance that resources are used economically and efficiently and that the City's objectives
are being achieved.
The Internal Audit Department has completed a performance audit of the utility payment
assistance program. We conducted this performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives.
Management Responsibility
City management is responsible for ensuring that resources are managed properly and used in
compliance with laws and regulations; programs are achieving their objectives; and services are
being provided efficiently, effectively, and economically.
Audit Objectives, Scope, and Methodology
The Internal Audit Department has completed an audit of the City's utility payment assistance
program including application management, pledge award administration, and program
effectiveness. This report is intended to provide assurance that the City has established adequate
processes and procedures to ensure the utility payment assistance program is managed efficiently,
effectively, and in accordance with contract terms.
Audit fieldwork was conducted during January, February and March 2021. The scope of review
varied depending on the procedure being performed. The following list summarizes major
procedures performed during this time:
• Reviewed documentation to develop criteria including contract terms, documented policies,
and procedures;
• Developed process narratives to identify current control activities in the utility payment
assistance process;
• Interviewed Customer Service and Interfaith Ministries of Denton staff;
• Inspected a statistical sample of 100 pledge recipients and 100 denied applicantS2 to ensure
they were awarded and managed in accordance with contract terms and documented policies
and procedures;
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'The City of Denton Internal Auditor's Office is considered structurally independent as defined by generally accepted government auditing
standard 3.56.
2 These samples provide with 95%confidence that the true population is±10%of the sample estimate.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
• Reviewed Interfaith Ministries of Denton bank statements to ensure all deposits, fund
transfers, and payments were appropriate;
• Examined supporting documentation for the sample of pledge recipients and denied
applicants;
• Reviewed customer utility account Promised Fund and Balance History data in the NorthStar
billing system; and
• Administered customer service surveys to a judgmental sample of 20 pledge recipients and 20
denied applicants from the period October 2020—December 2020.
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The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Findings & Analysis
In 1998,the City of Denton established a utility payment assistance program known as Prevent Loss
of Utility Service, or PLUS One.This program was originally designed to provide an avenue for the
City's utility customers to donate money to assist other Denton residents in need. Currently, the
City still receives about $7,800 in donations annually for this program annually; however, the
majority of PLUS One assistance is funded by Denton Municipal Electric revenues as illustrated in
Figure 1.
Figure 1: PLUS One Program Funding Summary3
$350,000
City Funding 'Customer Donations Assistance Disbursed
$300,000
$250,000
$200,000
$150,000
$100,000
$50,000
$0
FY17-18 FY18-19 FY19-20
Since the establishment of the PLUS One Program,the City has contracted with Interfaith Ministries
of Denton to administer and distribute these funds. Interfaith Ministries is a local non-profit
organization that also provides general assistance to local residents and households such as food,
transportation assistance, personal hygiene supplies, and more.
Based on review of peer cities,4 Denton is the only municipality with an established city-funded and
promoted utility payment assistance program for its utility customers. Other peer cities generally
promote assistance offered by local charities or distribute federal assistance received due to
COVID-19. It should be noted that not all the peer cities reviewed own and operate electric and
water utilities.
This audit generally evaluated all parts of the City's utility payment assistance program including
application management,documentation retention,award processing,and program effectiveness.
Assistance Awards Generally Supported; Some Record Improvements Needed
In order to receive utility payment assistance from the PLUS One Program, a person must be an
authorized City of Denton utility customer. Each customer then applies for assistance through
Interfaith Ministries who determines if they are eligible for the Program based on information
received from the Customer. In order to receive a pledge for utility payment assistance, the (,Q
customer must provide identification documentation and evidence of a financial hardship. A copy
of the customer's utility bill is provided by the City's Customer Service Division on request. a
3 In September 2020,the City allocated an additional$100,000 to aid households affected by COVID-19 financial hardships.
4 Peer cities reviewed included:Killeen,McAllen,Mesquite,Midland,Waco,Richardson,Odessa,College Station,and Lewisville.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
If a pledge is awarded, Interfaith notifies Customer Service to apply the pledge amount to the
customer's account with a Pledge Letter. Each week, Interfaith sends the City a check to cover the
outstanding pledged amounts. This process is illustrated in Figure 2.
Figure 2: Utility Payment Assistance Process
Interfaith
• Submit Ministries Apply Pledge to
Screening Form • Determine Account
&Application Elgibility • Process Pledge
• Award Pledge & Check
Customer
Issue Check
ServiceD
What We Found
• Over the last two fiscal years, Interfaith has awarded assistance to just over 800 unique
households, while just over 900 additional assistance applications were denied for various
reasons as shown in Figure 3.
Figure 3: Assistance Application Outcome Summary(FY2018-19 & 2019-20)
isted Non-Responsive
HouseholdsDenials
37
Inadequate
Documentation
14%
Ineligible
2%
• Interfaith Ministries receives and manages all applications for the City's utility payment
assistance program, including documentation supporting each awarded pledge. Interfaith has
developed an Assistance Handbook to assist staff when processing applications.
o Prior to September 2018, this documentation was maintained on a case management
software published and maintained by a non-profit organization. According to
Interfaith staff, this non-profit shut down and all prior case documentation was lost.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
o Currently, Interfaith utilizes the US Department of Housing and Urban Development's
Homeless Management Information System to receive and process PLUS One
assistance applications. The Assistance Handbook has not been updated to reflect
these changes in procedure.
o In addition, Interfaith staff now track applications using a Client Log, which must be
manually updated if there is a change in an application's status. Based on review of
this Client Log, there is inconsistent log documentation for each application including
some missing information on the actions taken for each application. Manual
maintenance of these logs increases the risk of data entry errors.
o Finally, the Homeless Management Information System does not allow for storage of
supporting documentation. For this reason, all documents supporting a pledge award
are maintained on Interfaith Ministries' local network.
• Based on a statistical sample of 100 customers who received assistance during 2019 and 2020,
Interfaith had retained all necessary support documentation for 80 percent of pledge
recipients. Table 1 below shows what documentation was missing for the remaining 20
percent.
Table 1: Pledge Award Documentation Sample Results
Missing Documentation Customers Assistance Value
None 80 $33,582
Identification 6 $2,489
Pledge Letter 6 $1,104
Evidence of Hardship 3 $1,038
Utility Bill Copy 2 $1,028
Check Request 2 $573
Case Notes 1 $1,048
All: 100 $40,454
o Based on review of the support documentation, most client files contained all required
support documentation; however, there were a few items identified that could
improve Interfaith's documentation consistency and improve program efficiency
related to pledge award cases.
o While only one pledge was completely missing case notes in the Homeless
Management Information System, many other case notes did not contain detailed
information regarding the applicant's financial hardship.As these notes can be utilized
by other agencies with access to the Homeless Management Information System,they
should be detailed enough for caseworkers to understand why all previous assistance
was received without firsthand knowledge.
Why It Matters
Interfaith Ministries is responsible for ensuring the PLUS One Program is administered in
accordance with contract terms. Applications must be processed and tracked consistently to
ensure all applications for awards are properly supported. While most awarded pledges had all 00
necessary documentation, inconsistencies in Homeless Management Information System case Q
notes may frustrate Interfaith Ministries and other agencies when attempting to understand why
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
utility payment assistance was awarded in the future. Similarly, while Interfaith must track its
applications, manually doing so in a separate Client Log creates a duplication of effort, which may
lead to data entry errors.
In addition, Interfaith's current documentation retention practices may hinder the City and other
external agencies from conducting reviews as documentation can be lost unexpectedly. In addition,
if the program is managed by another agency in the future,transitioning relevant case information
and support documentation may be difficult.
Finally, documented policies and procedures help an organization retain institutional knowledge,
navigate emergency situations, and facilitate consistency. This is particularly important when an
organization is comprised of volunteers with potentially high turnover, manages multiple different
assistance programs, and receives a relatively high volume of client inquiries and applications. For
this reason, the Interfaith Ministries Assistance Handbook should be periodically reviewed and
updated as needed.
Recommendations:
1. Provide written guidance to staff on what details should be included in Homeless Management
Information System case notes to ensure consistency and understandability. Periodically
providing training to staff may also facilitate consistency.
Interfaith Ministries of Denton Comments: IFM will develop a checklist of basic items to include
in case notes. Caseworkers are also provided training through the Texas Homeless Network
when any changes occur in the HMIS system.
2. Evaluate the use of the Client Log to track client information and status notes. Consider adding
columns to minimize the need for manual notes and reduce the possibility for error.
Interfaith Ministries of Denton Comments: We are already working with Customer Service to
simplify the call log and help prevent duplication of effort. We are happy to consider the
feasibility of any specific changes recommended by the City.
3. Collaborate with the Customer Service Division to determine if support documentation for
awarded pledges should be retained by the City.
Interfaith Ministries of Denton Comments: IFM currently sends pledges, copies of checks and
copies of the customer bills to Customer Service. IFM is happy to send any additional
documentation that Customer Service deems necessary.
Customer Service Division Comments: While Customer Service does concur that a formal backup
method should be explored, we have concern for any retention of documentation for pledges
by the City as those documents contain sensitive records for customers for which the City has
other purposes for possessing.
4. Periodically review and update the Assistance Handbook to ensure it reflects current
processes.
Interfaith Ministries of Denton Comments: IFM will update the Assistance Handbook when any
major change in program occurs. w
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Awarded Pledges Largely Applied to Utility Accounts Appropriately
Once a customer is awarded a utility payment assistance pledge, the City's Customer Service
Division is notified by a Pledge Letter. At this time, the Division applies the promised funds to the
accounts, helping ensure customers are not charged additional late fees or interruptions to service.
Customer Service then processes pledged payments similarly to how other utility payments are
processed once received.
What We Found
• Customer Service has developed Standard Operating Procedures that detail the Pledge Letter
and payment application process. These procedures appear to be up-to-date and provide
assurance that the process is completed effectively and consistently.
o These procedures also include a process to identify all pledges that have yet to be paid
each month.These reports appear to be run appropriately.
• Based on a statistical sample of 100 customers who received assistance during 2019 and 2020,
two customer utility accounts did not appear to be updated correctly in the City's utility billing
system.
o Specifically, one account appeared to have two pledge payments processed to the
account of $100 when only one pledge was awarded, and one account received the
pledge payment, but the pledge award was missing in the utility billing system. Based
on discussion with Customer Service staff, these issues appear to generally be related
to the influx of requests due to the COVID-19 Pandemic.
• Additionally, Customer Service staff stated that there had been occasions where a customer's
utility account had closed soon after they received PLUS One Program assistance. This had
sometimes caused the customer to be refunded PLUS One funds.
o This issue was not observed for any of the customers included in the statistical sample;
however,the refund process should be updated to ensure these instances are handled
appropriately, even if rare.
Why It Matters
In general, the Customer Service Division appears to process and apply utility payment assistance
pledges appropriately.This helps to ensure that pledged payments have been applied to awarded
customer accounts in a timely manner. Furthermore,Customer Service appears to have developed
effective procedures to ensure that pledges are processed consistently; however, procedures do
not include steps to check for awarded pledges before issuing a refund. Ensuring that PLUS One
assistance funds are not refunded to customers who close their accounts will allow the City to assist
additional customers in these rare instances.
Recommendation:
5. Develop a process to ensure customer account refunds are reviewed for utility payment
assistance pledge awards prior to processing the refund to ensure each case is reviewed and 0
handled appropriately. Document this process and include a periodic review to update as a,
to
necessary.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Customer Service Division Comments: Customer Service has a practice in place to address this
issue; however, concurs with the recommendation to formalize the process to ensure excess
pledge funds are not refunded to customers upon account closure.
Assistance Restricted to Once a Year; Extreme Hardship Exception Used Frequently
The City's contract with Interfaith Ministries generally limits the number of times a utility customer
may be assisted to once per year. This limit generally aligns with the Programs stated purpose to
assist residents experiencing "short-term financial emergencies" from time-to-time. The contract
does include an exception to this limit if the customer is "designated as an extreme hardship," in
which case the customer may receive assistance up to three times a year. Interfaith Ministries'
Assistance Handbook requires that these exceptions be approved by the organization's Executive
Director. Figure 4 illustrates the total pledges made to households for the past three calendar years
by designation.
Figure 4: Assistance Pledges Awarded
600
■Extreme Hardship Assistance Awards ■Standard Hardship Assistance Awards
500
400
300 -
200
100
0
2018 2019 2020
What We Found
• While the City's contract with Interfaith Ministries allows exceptions to the annual assistance
limit for those designated with an extreme hardship, it does not include guidelines or criteria
clarifying what constitutes as an extreme hardship.
• Based on a statistical sample of 100 customers who received assistance during 2019 and 2020,
35 were awarded assistance more than once within a 12-month period. Per contract
guidelines, applicants should be designated as having an "extreme hardship."
o Based on review of the award support documentation, there was no differentiating
documentation or formal justification to support the extreme hardship designation for
30 of these customers. For the remaining five customers, the Pledge Letters were
submitted by Interfaith Ministries Executive Director, indicating the designation was
approved per Interfaith's procedures.
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The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
• Based on a review of utility cut off data, about 6 percent of the City's utility customers
experienced at least one service interruption between 2018 and 2020;5 almost 99 percent of
these cut offs were performed on residential accounts.
o Of those utility accounts that experienced a cut off, almost 60 percent experienced
more than one cut off per year; on average, these accounts experience about three
service interruptions annually.
Why It Matters
It is important to ensure the utility payment assistance program is administered to customers
equitably in order to be effective.The extreme hardship exception facilitates this goal, as it allows
Interfaith Ministries to provide additional assistance to those customers who have greater need.
That being said, without formal guidance on what is considered an extreme hardship or
documented justification and approval, use of this exception is vulnerable to misuse.
Furthermore, the majority of Denton utility customers who experience service interruptions,
experience more than one each year. While these "frequently cut" accounts only make up 2
percent of all utility customers, restricting the number of times assistance may be awarded could
negatively impact these community members. On the other hand, expanding or eliminating
assistance restrictions may have a negative impact on customers experiencing one-off, short-term
financial emergencies as Program funding is limited.These factors are important to consider when
defining the extreme hardship designation and considering the PLUS One Program's intended
impact.
Recommendations:
6. Evaluate the current extreme hardship exception to determine if it is effective.
Customer Service Division Comments: Customer Service concurs that the extreme hardship
qualification is vague and ineffective. Staff will review and implement more direct language in
the contract or some other alternative that ensure clarity and program effectiveness.
7. Develop guidelines and criteria to formally document extreme hardship justification and
approval.
Interfaith Ministries of Denton Comments: IFM is working with the City to see if there is a need
for hardship guidelines, since most customers assisted already fall into that category by virtue
of their incomes. Once we receive written guidelines from the City, we will incorporate it into
our policies. IFM request that any changes in the guidelines and criteria be communicated in
writing by the City.
Assistance for Program Employees Need Further Oversight
Interfaith Ministries Assistance Handbook has documented guidelines for processing assistance
applications submitted by Interfaith Ministries staff(i.e. employees or volunteers). These staff are N
required to disclose any conflicts of interest when processing assistance applications and ensure
the application is approved by an employee without a conflict.
5 About 96 percent of service interruptions are resolved within one day and all interruptions were resolved within one week.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
What We Found
• Based on review of assistance awarded by Interfaith Ministries between fiscal year 2017-18
and fiscal year 2019-20, two Interfaith Ministries employees received six PLUS One Program
awards for a total of$1,257.
o Based on review of the supporting documentation of these pledge awards provided by
Interfaith Ministries,6 evidence of the financial hardship being experienced was not
provided and was only documented in the Homeless Management Information System
case notes.
o Furthermore, no other pledge recipients received assistance for financial hardships
similar to one of Interfaith Ministries employees. For example, issues experienced by
other utility pledge award recipients included:job loss; unemployment benefits denial;
reduced work hours; unexpected household or car repairs; death of a spouse; and
emergency medical expenses. The justification noted for the Interfaith Ministries
employee was, "Client had to buy school supplies, clothes, &shoes for 10 yo son going
back to school."
o In addition,while the case notes entered into the Homeless Management Information
System stated that Interfaith Ministries Executive Director approved the pledges, this
approval was not otherwise documented.
o Finally, some identification documentation that is typically required was not available
for the two assisted Interfaith employees.
• One Customer Service employee received two pledge awards totaling $1,009 during 2019.
Based on review of the support documentation obtained from Interfaith Ministries,all required
documentation was available.
o Moreover, Customer Service has established controls and processes to mitigate risks
related to utility billing system access as discussed in the Customer Service Division
Audit (Dec. 2018) and Follow-Up Review (June 2020). Based on review, these
established controls and processes appear to minimize the risks associated with
employees having the ability to update their own utility accounts.
Why It Matters
All eligible Denton utility customers should be able to receive utility payment assistance; however,
due to the level of access and involvement that Interfaith Ministries staff have in the PLUS One
Program, additional controls should be implemented to minimize the appearance of and risk of
fraud or abuse. Interfaith Ministries' employee applicants should be required to provide the same
level of documentation as all other applicants and additional, documented review and approval
may be necessary.
Recommendation:
8. Coordinate with City staff to develop a review process for Interfaith Ministries' employee
applicants of the utility payment assistance program. m
6 Supporting documentation from one award could not be reviewed due to the organizations previous case management system shutting down.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Interfaith Ministries of Denton Comments: This sounds like an excellent idea. It has been
suggested by the City that IFM employee assistance requests be reviewed by the Revenue
Service Supervisor and IFM is in agreement.
Customer Service Division Comments:Customer Service concurs and will partner with Interfaith
Ministries of Denton to implement a means to ensure any pledges awarded to Interfaith
employees and/or volunteers who require utility assistance are done so transparently, equitably
when compared to other customers, and in full compliance with the program.
Interfaith Has Begun Addressing Suggested Customer Service Improvements
The City's Customer Service Division conducted a review of Interfaith Ministries general operations
and customer service in March 2019.The review found five customer service issues and requested
that Interfaith Ministries provided an action plan to resolve the findings, including:
➢ Response to customers is made in a timely manner preferably within 1-2 business days;
Ensuring customer messages are returned preferably within 1-2 business days;
➢ Phone recordings contain clear information which matches the website;
➢ Including closure information and holiday schedule on the website; and
➢ Review website and correct discrepancies such as the hours of operation found on the
Contact Us and Apply for Assistance sections of the website.
What We Found
• In response to this review, Interfaith Ministries agreed to implement the following processes:
o Hold quarterly customer service trainings for Interfaith Ministries employees and
volunteers.
■ According to Interfaith Ministries' Executive Director, customer service
trainings have not been conducted since the beginning of the COVID-19
Pandemic due to safety concerns. Prior to this,trainings had been conducted;
however, attendance and content were not documented.
o Update phone technology to allow for the recording of calls, which would allow for
quality assurance reviews to be conducted.
■ The phone system appears to have been updated. According to the Interfaith
Ministries' Executive Director, phone calls are periodically reviewed to ensure
staff are providing adequate customer service; however, a written procedure
for conducting and documenting these reviews has not been developed.
■ Interfaith Ministries also offers an optional, anonymous customer service
survey to its clients. The results of these surveys are generally reported to
Interfaith Ministries' Executive Board quarterly. Interfaith Ministries provided
15 months of customer service survey results for November 2018 through
January 2020 as part of this audit; however, these results were not previously
been reported to the City. This reporting is required by the current contract
with the City.
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o Update website information to ensure it is accurate.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
• Based on review of the Interfaith Ministries website during the audit period,
holiday closures were not posted and staffing information was not up to date.
These issues were promptly addressed by Interfaith staff once notified.
• Based on a customer service survey administered by Internal Audit during February 2021,7100
percent of respondents believed Interfaith Ministries had treated them with dignity and
respect during their interactions, including those that were denied assistance.
o Four of six denied applicants noted that they were not informed of the reason for
denial; however, it should be noted that two of these applicants were denied due to
non-responsiveness.
Why It Matters
As an external, contracted agency on behalf of the City, Interfaith Ministries has a responsibility to
provide satisfactory service to applicants and potential applicants of the utility payment assistance
program as these services reflect the City. Interfaith Ministries appears to have resolved much of
the customer service-related issues noted by the City's previous review. Still, regular customer
service training should be provided to ensure staff stay up to date on customer service best
practices. This may also benefit Interfaith Ministries with potential donations, volunteers and
return clients if satisfied with the customer service received.
Similarly, developing a process to review client phone calls regularly will provide further assurance
of customer service quality and information accuracy. Reporting on feedback from clients on their
experiences with Interfaith Ministries allows the City to effectively monitor the quality of customer
service provided on their behalf and fulfills a contractual obligation.
Finally, applicants that are denied for the utility payment assistance program should be informed
of the reason for denial so that potential errors can be corrected. Although many denials are due
to non-responsiveness, these instances should be clearly documented in the Client Log in case an
applicant contacts Interfaith once denied.
Recommendations:
9. Ensure denied applicants are provided updates so they understand the reason for being denied
assistance. Denial reasons should also be clearly documented in the Client Log even if they
were denied due to non-responsiveness.
Interfaith Ministries of Denton Comments: Potential applicants are already informed during
screening and during referral by the City that failure to respond or provide requested
documentation by a specific date will result in denial. However, we will also send an email to
them when an email address is available.
10. Establish a process to periodically provide customer service training to staff. Attendance and
training content should be documented. Ll)
7-1
Interfaith Ministries of Denton Comments: IFM resumed this practice on 3117121 and will a
continue quarterly training.
7 Forty assistance applicants,half of whom received assistance and half of whom were denied,were surveyed.Each applicant was called at least
two times at different periods of the day.Twelve assistance recipients and six denied applicants responded to the survey.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
11. Develop a process to regularly track and monitor client calls for content accuracy and customer
service quality.
Interfaith Ministries of Denton Comments:A review plan was developed 3122121. IFM's Director
has begun reviewing 4-6 random calls per week for content accuracy and customer service
quality.
12. Begin providing quarterly reports on customer service survey responses to the City as required
by contract.
Interfaith Ministries of Denton Comments: Our customer service survey is optional to
customers. We provided 15 months of survey response results to the City Auditor. We would be
glad to provide those and any future responses to the City upon clarification as to whom they
should be submitted.
Public Outreach Efforts are Broadly Effective; but Not Coordinated or Data Informed
According to the City's contract with Interfaith Ministries, the PLUS One Program is intended to
"ensure that the utility bills for some of the area's less fortunate families are paid so they can keep
cool in the summer and warm in the winter." In order to be effective in this effort, customers must
be informed of the PLUS One Program so that they may apply when assistance is needed.
In addition,assistance should generally be awarded equitablyto Denton utility customers who have
greater need. The City's PLUS One Program contract generally gives priority to residential
households with gross family income at 65 percent or less of the area median income, with
members who have serious illness, disability, or small children, and that have experienced recent
emergencies.
What We Found
• Based on discussions with Interfaith Ministries and City staff, there is no coordinated public
outreach effort to inform residents about the PLUS One Program. According to Interfaith
Ministries staff, they attended community events before the COVID-19 Pandemic to promote
the organization's assistance efforts, including but not limited to the PLUS One Program.
o Based on a customer service survey administered by Internal Audit during February
2021, about 60 percent of respondents said they heard about the PLUS One Program
informally from friends, community groups, etc.
o The Customer Service Division does direct utility customers to Interfaith Ministries and
may complete the customer's screening application if they express interest in utility
payment assistance.
• In order to facilitate monitoring of the PLUS One Program's effectiveness, Interfaith Ministries
is required to submit monthly reports on assistance applications, including recipients'
demographic information.
o Based on conversations with Customer Service Division staff, this information is Q0
generally not analyzed or utilized to further enhance program effectiveness.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
o Demographic information for customers denied assistance is not collected or reported.
This is due, in part, to many applicant denials being due to non-responsiveness. In
addition, collection of demographic information before assistance is awarded may
deter some people from applying.
• To assess the effectiveness of limited public outreach efforts and equity of assistance, Internal
Audit compared assistance demographic information to the City of Denton's Comprehensive
Housing Affordability Strategy data.$This comparison is intended to account for greater need
as prioritized by income and is illustrated in Figure 5.
Figure 5:Assistance Race & Ethnicity Benchmark Comparison (FY 2020)9
■White ■Hispanic ■Black ■Asian ■Other
20%
15%
10%
5% Ilion 1111mi-pr ' III M
0/°
Assisted Benchmark Assisted Benchmark Assisted Benchmark Assisted Benchmark
Extremely Low Very Low Low Moderate
Income Level
o In general, this comparison shows that white and Asian people appear to receive
assistance less frequently at all income levels than would be expected in comparison
to the benchmark. On the other hand, Hispanic and Black people appear to receive
assistance more frequently at the extremely low- and very low-income levels, but at
the relatively expected frequency at the low-and moderate-income levels.
■ These discrepancies appear to be in part explained by the Program prioritizing
lower income households.10 In particular, 85 percent of assisted households
had extremely low or low income, whereas these income levels only make up
54 percent of households below the City's median income.
■ Similarly, the Consolidated Plan identifies racial or ethnic groups that appear
to be facing increased need by comparing the percentage of each group
experiencing housing problems11 to the whole income level. Table 2
summarizes this analysis from the City's Consolidated Plan for Housing and r—I
Community Development:
8 This data is collected by the US Census Bureau and is used in the City's Consolidated Plan for Housing and Community Development as required
by the US Department of Housing and Urban Development.
9 Based on the Consolidated Plan data,individuals and households of Indigenous,Pacific Islander,Multi-Racial and Unknown race and ethnicity
were combined into an Other category to ensure comparisons could be made with adequate data.Between FY2017-18 and FY2019-20,14
Indigenous people,two Pacific Islanders,and 25 Multi-Racial people received PLUS One Program assistance.
10 Black and Asian households make up an increasingly lower percentage of households as income level increase while white households make
up an increasingly larger percentage.On the other hand,Hispanic households make up a relatively similar percentage of households at every
income level.
11 The Consolidated Plan defines four housing problems:1)lacks complete kitchen facilities,2)lacks complete plumbing facilities,3)more than
one person per room,and 4)cost burden greater than 30 percent.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Table 2: Housing Problem Analysis by Race & Ethnicity and by Income Level12
Income Level White Hispanic Black Asian All
Extremely Low 87% 93% 85% 66% 86%
Very Low 81% 79% 83% 91% 81%
Low 44% 40% 59% 45% 45%
Moderate 21% 22% 16% 37% 21%
All: 60% 62% 69% 64% 62%
o Based on this information, the PLUS One Program appears to more frequently assist
those with greater need,as indicated by income level and housing problems; however,
the City's Asian communities appear to have been awarded assistance less frequently
than expected. This may indicate a need for greater outreach to the City's Asian
communities.
Why It Matters
The utility payment assistance program was developed to assist Denton utility customers
experiencing financial hardship with their utility bills to avoid service interruptions. Interfaith
Ministries Monthly Reports contain applicant data that is necessary to measure program
effectiveness. Analyzing this information would allow the City to establish performance measures
and develop outreach plans to target communities considered to have greater need.
Recommendation:
13. Establish a process to utilize the data included in Interfaith Ministries' Monthly Reports to
enhance program effectiveness by identifying Program promotion opportunities and focusing
on households and communities with greater need.
Customer Service Division Comments:Customer Service concurs. Staff agrees with the need for
greater program promotion, but believes the data from Interfaith would not, in and of itself,
provide sufficient guidance on how to target communications toward demographics. Customer
Service will meet this recommendation by, on an ongoing basis, utilizing census housing and
income information, focusing on distribution of information to other agencies which serve
households that fall within assistance thresholds, and using other available resources to drive
targeted communication opportunities. Staff will additionally explore any other opportunities
for general communications.
Expanding Program Reconciliation Procedures Would Provide Further Assurance
Interfaith Ministries maintains a separate bank account for received PLUS One Program funds.
Payments for allocated program funding and administrative costs are issued to Interfaith through
the City's general purchase order process. Additionally, assistance checks are issued from this
account. 00
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12 In Table 2,the race and ethnic groups highlighted appear to experience housing problems significantly more frequently than other groups at
that income level.Per the Consolidated Plan,if at least 10 percent more of a group's households experience housing problems than the income
level average it is considered a significant difference.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
What We Found
• Based on a review of Interfaith Ministries' bank statements for January 2018 through
December 2020, the PLUS One bank account appears to be managed effectively and no
inappropriate transactions were identified.
• The Customer Service Division currently reviews Interfaith Ministries' Monthly Reports to
ensure total reported pledge awards match the total award payments received each month.
Any identified discrepancies are corrected with Interfaith as needed.
o Based on review of a statistical sample of 100 pledge recipients, one recipient's pledge
was documented incorrectly in Interfaith Ministries' Monthly Report; however, the
approved pledge amount was processed correctly on their utility account.
o The Customer Service Division does not obtain or review Interfaith Ministries bank
statements.
Why It Matters
Interfaith Ministries and the City of Denton have a fiduciary responsibility to Denton utility
customers and PLUS One Program donors to ensure funds are spent appropriately. For this reason,
funds should be monitored and reconciled on a regular basis to provide assurance that the Program
is being administered efficiently and effectively and in compliance with the Program's purpose.
While the City does currently reconcile assistance pledges to payments, obtaining and reviewing
the monthly bank statement will provide additional assurance that Program funds are being
managed appropriately and are not misused.
Recommendation:
14. Obtain Interfaith Ministries' PLUS One bank statement monthly to provide further assurance
that that assistance funds spent appropriately. Bank statements should be used to enhance
current reconciliation procedures, which should be updated appropriately.
Customer Service Division Comments: Customer Service concurs with the value of statement
review and will work with Interfaith Ministries to obtain the documents monthly.
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The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Appendix A: Management Response Summary
The following summarizes the recommendations issued throughout this report. The auditors found that
staff and the Department were receptive and willing to make improvements to controls where needed.
Management has provided their response to each recommendation.
Provide written guidance to staff on what details should be Expected
included in Homeless Management Information System case Completion:
1 notes to ensure consistency and understandability. Concur 4/30/21
Periodically providing training to staff may also facilitate
consistency.
Interfaith Ministries of Denton Comments: IFM will develop a checklist of basic items to Responsibility:
include in case notes. Caseworkers are also provided training through the Texas IFM Director
Homeless Network when any changes occur in the HMIS system. and staff and
THN
Evaluate the use of the Client Log to track client information Expected
2 and status notes. Consider adding columns to minimize the Concur Completion:
need for manual notes and reduce the possibility for error. 5/31/21
Interfaith Ministries of Denton Comments: We are already working with Customer Responsibility:
Service to simplify the call log and help prevent duplication of effort. We are happy to IFM Director
consider the feasibility of any specific changes recommended by the City. and Staff with
input from
City
Collaborate with the Customer Service Division to determine if Expected
3 support documentation for awarded pledges should be Partially Concur Completion:
retained by the City. 6/30/21
Interfaith Ministries of Denton Comments: IFM currently sends service pledges, copies Responsibility:
of checks and copies of the customer bills to Customer Service. IFM is happy to send IFM Director
any additional documentation that Customer Service deems necessary. and Customer
Customer Service Division Comments: While Customer Service does concur that a Service
formal backup method should be explored,we have concern for any retention of Manager
documentation for pledges by the City as those documents contain sensitive records for
customers for which the City has no other purpose for possessing.
Expected
Periodically review and update the Assistance Handbook to Completion:
4 ensure it reflects current processes. Concur 6/30/21 &
Ongoing
Interfaith Ministries of Denton Comments: IFM will update the Assistance Handbook Responsibility:
when any major change in program occurs. IFM Director
with input
from staff
Develop a process to ensure customer account refunds are Expected
reviewed for utility payment assistance pledge awards prior to Completion:
5 processing the refund to ensure each case is reviewed and Concur 4/30/21 CD
handled appropriately. Document this process and include a
periodic review to update as necessary.
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Customer Service Division Comments: Customer Service has a practice in place to Responsibility:
address this issue; however, concurs with the recommendation to formalize the process Credit&
to ensure excess pledge funds are not refunded to customer upon account closure. Collections
Specialist
Evaluate the current extreme hardship exception to determine Expected
6 Concur Completion:
if it is effective. 5/31/21
Customer Service Division Comments: Customer Service concurs that the extreme Responsibility:
hardship qualification is vague and ineffective. Staff will review and implement more Dir. Of
direct language in the contract or some other alternative to ensure clarity and program Customer
effectiveness. Service &
Public Affairs
Develop guidelines and criteria to formally document extreme Expected
7 hardship justification and approval. Partially Concur Completion:
5/30/21
Interfaith Ministries of Denton Comments: IFM is working with the City to see if there is Responsibility:
a need for hardship guidelines, since most customers assisted already fall into that IFM and City
category by virtue of their incomes. Once we receive written guidelines from the City, staff
we will incorporate it into our policies. IFM requests that any changes in the guidelines
and criteria be communicated in writing by the City.
Coordinate with City staff to develop a review process for Expected
8 Interfaith Ministries'employee applicants of the utility Concur Completion:
payment assistance program. 5/31/21
Interfaith Ministries of Denton Comments:This sounds like an excellent idea. It has Responsibility:
been suggested by the City that IFM employee assistance requests be reviewed by the IFM and Dir.
Revenue Service Supervisor and IFM is in agreement. Of Customer
Customer Service Division Comments: Customer Service concurs and will partner with Service &
Interfaith Ministries of Denton to implement a means to ensure any pledges awarded Public Affairs
to Interfaith employees and/or volunteers who require utility assistance are don so
transparently, equitably when compared to other customers, and in full compliance
with the program.
Ensure denied applicants are provided updates so they Expected
9 understand the reason for being denied assistance. Denial Partially Concur Completion:
reasons should also be clearly documented in the Client Log 4/1/21
even if they were denied due to non-responsiveness.
Interfaith Ministries of Denton Comments: Potential applicants are already informed Responsibility:
during screening and during referral by the City that failure to respond or provide IFM staff and
requested documentation by a specific date will result in denial. However, we will also Customer
send an email to them when an email address is available. Service
Establish a process to periodically provide customer service Expected
10 training to staff.Attendance and training content should be Concur Completion:
documented. 3/24/21 and
Ongoing rl
Interfaith Ministries of Denton Comments: IFM resumed this practice on 3/17/21 with Responsibility: N
complete documentation IFM Director
The City of Denton Internal Audit Report April 2021
Audit of Utility Payment Assistance Program
Develop a process to regularly track and monitor client calls Expected
11 for content accuracy and customer service quality. Concur Completion:
3/22/21
Interfaith Ministries of Denton Comments:A review plan was developed 3/22/21. IFM's Responsibility:
Director has begun reviewing 4-6 random calls per week for content accuracy and IFM Director
customer service quality.
Begin providing quarterly reports on customer service survey Expected
12 responses to the City as required by contract. Concur Completion:
6/15/21
Interfaith Ministries of Denton Comments: Our customer service survey is optional to Responsibility:
customers. We provided 15 months of survey response results to the City Auditor. We IFM Director
would be glad to provide those and any future responses to the City upon clarification and Staff
as to whom they should be submitted.
Establish a process to utilize the data included in Interfaith Expected
13 Ministries'Monthly Reports to enhance program effectiveness Concur Completion:
by identifying Program promotion opportunities and focusing Ongoing
on households and communities with greater need.
Customer Service Division Comments: Customer Service concurs. Staff agrees with the Responsibility:
need for greater program promotion, but believes the data from Interfaith would not, Customer
in and of itself, provide sufficient guidance on how to target communications toward Service
demographics. Customer Service will meet this recommendation by, on an ongoing Manager&
basis, utilizing census housing and income information,focusing on distribution of Dir. Of
information to other agencies which serve households that fall within assistance Customer
thresholds, and using other available resources to drive targeted communication Service &
opportunities. Staff will additionally explore any other opportunities for general Public Affairs
communications.
Obtain Interfaith Ministries'PLUS One bank statement Expected
monthly to provide further assurance that that assistance Completion:
14 funds spent appropriately. Bank statements should be used to Concur 4/30/21
enhance current reconciliation procedures, which should be
updated appropriately.
Customer Service Division Comments: Customer Service concurs with the value of Responsibility:
statement review and will work with Interfaith Ministries to obtain the documents Business
monthly. Information
Analyst
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