Audit 15062

FY End
2022-06-30
Total Expended
$5.35M
Findings
10
Programs
3
Organization: Pittsfield Housing Authority (RI)
Year: 2022 Accepted: 2024-02-01
Auditor: Marcum LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
11258 2022-001 Material Weakness - E
11259 2022-002 Material Weakness - N
11260 2022-003 Material Weakness - E
11261 2022-004 Material Weakness - L
11262 2022-004 Material Weakness - L
587700 2022-001 Material Weakness - E
587701 2022-002 Material Weakness - N
587702 2022-003 Material Weakness - E
587703 2022-004 Material Weakness - L
587704 2022-004 Material Weakness - L

Programs

ALN Program Spent Major Findings
14.871 Section 8 Housing Choice Vouchers $4.45M Yes 3
14.850 Public and Indian Housing $61,904 Yes 0
14.872 Public Housing Capital Fund $55,309 - 0

Contacts

Name Title Type
NGFXCE3QD1E8 Susan Martion Auditee
4134435936 Michael Guyder Auditor
No contacts on file

Notes to SEFA

Accounting Policies: NOTE 1 – BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Pittsfield Housing Authority, under programs of the federal government for the year ended June 30, 2022. The information in the schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of Pittsfield Housing Authority, it is not intended to and does not present the financial position, changes in net position or cash flows of Pittsfield Housing Authority. NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Expenditures reported on the schedule are reported on the accrual basis of accounting. For cost-reimbursement awards, such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. For performance-based awards, expenditures reported represent amounts earned. De Minimis Rate Used: N Rate Explanation: NOTE 3 – INDIRECT COST RATE The Pittsfield Housing Authority has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance.

Finding Details

2022-001 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 982.516). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 982.201, 982.515, 982.516). CONDITION As a result of our procedures, we identified five instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent and the housing assistance payment was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 25 vouchers from a population of 498. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-002 – SPECIAL TESTS & PROVISIONS: RENT REASONABLENESS Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster CRITERIA The PHA may not approve a lease until the PHA determines that the initial rent to an owner is a reasonable rent. (2) The PHA must redetermine the reasonable rent: (i) Before any increase in the rent to an owner; (ii) If there is a 10 percent decrease in the published FMR in effect 60 days before the contract anniversary (for the unit size rented by the family) as compared with the FMR in effect 1 year before the contract anniversary. (iii) If directed by HUD. The PHA may also redetermine the reasonable rent at any other time. At all times during the assisted tenancy, the rent to owner may not exceed the reasonable rent as most recently determined or redetermined by the PHA. (24 CFR 982.507) CONDITION The Authority did not perform rent reasonableness assessments. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS Questioned costs - $3,874,736. CONTEXT We selected a sample of 25 vouchers from a population of 498. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-003 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.850– Public and Indian Housing CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 960.259). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 960.253, 960.255, 960.259). CONDITION As a result of our procedures, we identified nine instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 16 tenants from a population of 152. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-004 – NONCOMPLIANCE: REPORTING Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster ALN #: 14.850– Public and Indian Housing CRITERIA Financial Reports (0MB No. 2535-0107) - Financial Assessment Sub- system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The FASSPH system is one of HUD's main monitoring and oversight systems for the HCV and PIH programs. CONDITION The Authority’s audited submission was not submitted by the deadline of March 31, 2023. CAUSE The Authority did not procure an auditor in a timely manner and was unable to submit the audited FDS by the deadline. EFFECT As a result of not submitting the FDS timely, HUD was limited in its ability to conduct monitoring and oversight of federal programs. QUESTIONED COSTS None noted. CONTEXT The Authority submits the audited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority improve the timing of the procurement process to ensure that the audited FDS is filed in a timely manner. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-004 – NONCOMPLIANCE: REPORTING Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster ALN #: 14.850– Public and Indian Housing CRITERIA Financial Reports (0MB No. 2535-0107) - Financial Assessment Sub- system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The FASSPH system is one of HUD's main monitoring and oversight systems for the HCV and PIH programs. CONDITION The Authority’s audited submission was not submitted by the deadline of March 31, 2023. CAUSE The Authority did not procure an auditor in a timely manner and was unable to submit the audited FDS by the deadline. EFFECT As a result of not submitting the FDS timely, HUD was limited in its ability to conduct monitoring and oversight of federal programs. QUESTIONED COSTS None noted. CONTEXT The Authority submits the audited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority improve the timing of the procurement process to ensure that the audited FDS is filed in a timely manner. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-001 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 982.516). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 982.201, 982.515, 982.516). CONDITION As a result of our procedures, we identified five instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent and the housing assistance payment was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 25 vouchers from a population of 498. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-002 – SPECIAL TESTS & PROVISIONS: RENT REASONABLENESS Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster CRITERIA The PHA may not approve a lease until the PHA determines that the initial rent to an owner is a reasonable rent. (2) The PHA must redetermine the reasonable rent: (i) Before any increase in the rent to an owner; (ii) If there is a 10 percent decrease in the published FMR in effect 60 days before the contract anniversary (for the unit size rented by the family) as compared with the FMR in effect 1 year before the contract anniversary. (iii) If directed by HUD. The PHA may also redetermine the reasonable rent at any other time. At all times during the assisted tenancy, the rent to owner may not exceed the reasonable rent as most recently determined or redetermined by the PHA. (24 CFR 982.507) CONDITION The Authority did not perform rent reasonableness assessments. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS Questioned costs - $3,874,736. CONTEXT We selected a sample of 25 vouchers from a population of 498. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-003 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.850– Public and Indian Housing CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 960.259). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 960.253, 960.255, 960.259). CONDITION As a result of our procedures, we identified nine instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 16 tenants from a population of 152. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-004 – NONCOMPLIANCE: REPORTING Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster ALN #: 14.850– Public and Indian Housing CRITERIA Financial Reports (0MB No. 2535-0107) - Financial Assessment Sub- system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The FASSPH system is one of HUD's main monitoring and oversight systems for the HCV and PIH programs. CONDITION The Authority’s audited submission was not submitted by the deadline of March 31, 2023. CAUSE The Authority did not procure an auditor in a timely manner and was unable to submit the audited FDS by the deadline. EFFECT As a result of not submitting the FDS timely, HUD was limited in its ability to conduct monitoring and oversight of federal programs. QUESTIONED COSTS None noted. CONTEXT The Authority submits the audited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority improve the timing of the procurement process to ensure that the audited FDS is filed in a timely manner. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-004 – NONCOMPLIANCE: REPORTING Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster ALN #: 14.850– Public and Indian Housing CRITERIA Financial Reports (0MB No. 2535-0107) - Financial Assessment Sub- system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The FASSPH system is one of HUD's main monitoring and oversight systems for the HCV and PIH programs. CONDITION The Authority’s audited submission was not submitted by the deadline of March 31, 2023. CAUSE The Authority did not procure an auditor in a timely manner and was unable to submit the audited FDS by the deadline. EFFECT As a result of not submitting the FDS timely, HUD was limited in its ability to conduct monitoring and oversight of federal programs. QUESTIONED COSTS None noted. CONTEXT The Authority submits the audited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority improve the timing of the procurement process to ensure that the audited FDS is filed in a timely manner. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.