Finding number: 2022-003 Federal program: 14.872 Public Housing Capital Fund (CFP) Category: Compliance - Cash Management Criteria or specific requirement: 24 CFR section 570.489 (c)(1) establishes that units of general local governments shall use procedures to minimize the time elapsing between the transfer of funds by the federal government and the disbursement made by the grantee. Condition: In testing compliance with the cash management requirement related to the time elapsed between the receiving of the request of funds from the federal government and the disbursement of funds; we observed that two (2) out of sixty (60) files requests of funds from the Capital Fund did not comply with the maximum three days of disbursement. In one instance, the days were exceeded by eight (8) days and in other instance by five (5) days. Questioned costs: No questioned costs were identified. Perspective information: We selected for testing sixty (60) requests from the Capital Fund out of 296 requests made during the year ended June 30, 2022. Cause: There was a lack of coordination by certain employees in charge of monitoring the time that elapsed between the cash requests and the disbursements of funds. Effect: In these instances, the Administration did not follow the established procedures to comply with 24 CFR, Section 570.489 (c) (1) to avoid requesting excess of cash. Recommendation: We recommend management to strengthen its disbursements procedures to minimize the time between the transfer of funds by the federal government and disbursements made by the PRPHA. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.
Finding number: 2022-001 Cluster: Housing Voucher Federal Programs: Assistance Listing 14.871 Section 8 Housing Choice Vouchers Category: Internal control ? control activities ? Eligibility Criteria or specific requirement: Title 2 2 CFR Part 200 Uniform Guidance section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal funds should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States (the Green Book) or the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations for the Treadway Commission (COSO). Condition: There were no formal written procedures outlining processes and control activities specific to the eligibility compliance requirement. Questioned cost: No questioned costs were identified. Cause: Management of these programs was assigned about a year ago to the Administration and formal procedures have not been implemented yet. Effect: There were no internal control measures documented that allow the Administration to timely prevent and/or detect a noncompliance with the eligibility compliance requirement and avoid possible sanctions or restrictions in the use of funds by the federal awarding entity. Recommendation: We recommend that the Administration design and implement control activities procedures to achieve the objectives and respond to the risks associated with the eligibility requirement. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.
Finding number: 2022-002 Cluster: Housing Voucher Federal Programs: Assistance Listing 14.871 Section 8 Housing Choice Vouchers Category: Internal control ? control activities ? Special tests and provisions (waiting list, reasonable rent, housing quality standards inspection, HQS enforcement and housing assistance payment) Criteria or specific requirement: Title 2 2 CFR Part 200 Uniform Guidance section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal funds should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States (the Green Book) or the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations for the Treadway Commission (COSO). Condition: There were no formal written procedures outlining processes and control activities specific to the special tests and provisions applicable to the program. Questioned cost: No questioned costs were identified. Cause: Management of these programs was assigned about a year ago to the Administration and formal procedures have not been implemented yet. Effect: There were no internal control measures documented that guide the manager of the federal program to timely prevent and/or detect a noncompliance with the special tests and provisions applicable to the program. Recommendation: We recommend that the Administration document the control activities procedures to achieve the objectives and respond to the risks associated with the areas involved in the special tests and provisions of the Housing Voucher program. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.
SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding number: 2022-005 Federal Program: Housing Voucher Cluster - 14.871 Section 8 Housing Choice Vouchers Category: Compliance and Internal Control ? Eligibility Criteria or specific requirement: 24 CFR part 5, subpart F sections 5.601, 982.201, 982.515 and 982.516 determine whether income eligibility and calculate the tenant?s rent payment were made using the documentation from a third-party verification. Condition: In testing compliance with the eligibility requirements related to income-eligibility and tenant?s rent payment, we noticed the following from the sample of sixty (60) files: ? In one (1) instance the participant?s pay stubs used as evidence of the income determination were for salaries received in 2020 when it should have been salary stub for 2021. ? Two (2) of the files examined did not have the last certification of the Nutrition Assistance Program (PAN) used in form 50058 to document total annual family income. ? In one (1) of the files examined the annual income received by the participant and documented in form 50058 was not properly calculated since the computation was made on a monthly basis instead of a weekly basis as the income was actually received by the participant. Questioned cost: No questioned costs were identified. Perspective information: We selected sixty (60) files of new tenants during 2021-2022 fiscal year from the Section 8 waiting lists. Cause: The Administration?s review process of the eligibility documentation in the files was not effective in these cases. Effect: Any error in income calculation and with the evidence presented by the participants could lead to wrong eligibility determination. Recommendation: We recommend the Administration to reinforce their internal control procedures in the review of the eligibility determination to avoid similar situations in the future. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.
Finding number: 2022-004 Federal program: Assistance Listing 21.023 Emergency Assistance Program Category: Internal control ? Eligibility and Reporting Criteria or specific requirement: Title 2 2 CFR Part 200 Uniform Guidance section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal funds should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States (the Green Book) or the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations for the Treadway Commission (COSO). Condition: There was no evidence of formal written procedures to monitor the evaluation of the eligibility determination of participants neither was written evidence to ensure that the reporting to the federal awarding agency was complete and accurate. Questioned costs: No questioned costs were identified. Perspective information: We selected a sample of testing sixty (60) requests of participants for rental assistance out of 16,320 requests made for the year. Also, we selected the ERAP special reports for its corresponding reporting compliance for the three-quarter submitted during the year ended June 30, 2022. Cause: This Federal program was recently assigned to the Administration and formal procedures have not been implemented yet. Effect: There were no monitoring activities documented that allowed the Administration to timely prevent or detect a noncompliance with the requirements of eligibility and reporting. Recommendation: We recommend that the Administration design and implement written procedures to monitor the processes of eligibility determination and the completion of special reports. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.
Finding number: 2022-003 Federal program: 14.872 Public Housing Capital Fund (CFP) Category: Compliance - Cash Management Criteria or specific requirement: 24 CFR section 570.489 (c)(1) establishes that units of general local governments shall use procedures to minimize the time elapsing between the transfer of funds by the federal government and the disbursement made by the grantee. Condition: In testing compliance with the cash management requirement related to the time elapsed between the receiving of the request of funds from the federal government and the disbursement of funds; we observed that two (2) out of sixty (60) files requests of funds from the Capital Fund did not comply with the maximum three days of disbursement. In one instance, the days were exceeded by eight (8) days and in other instance by five (5) days. Questioned costs: No questioned costs were identified. Perspective information: We selected for testing sixty (60) requests from the Capital Fund out of 296 requests made during the year ended June 30, 2022. Cause: There was a lack of coordination by certain employees in charge of monitoring the time that elapsed between the cash requests and the disbursements of funds. Effect: In these instances, the Administration did not follow the established procedures to comply with 24 CFR, Section 570.489 (c) (1) to avoid requesting excess of cash. Recommendation: We recommend management to strengthen its disbursements procedures to minimize the time between the transfer of funds by the federal government and disbursements made by the PRPHA. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.
Finding number: 2022-001 Cluster: Housing Voucher Federal Programs: Assistance Listing 14.871 Section 8 Housing Choice Vouchers Category: Internal control ? control activities ? Eligibility Criteria or specific requirement: Title 2 2 CFR Part 200 Uniform Guidance section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal funds should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States (the Green Book) or the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations for the Treadway Commission (COSO). Condition: There were no formal written procedures outlining processes and control activities specific to the eligibility compliance requirement. Questioned cost: No questioned costs were identified. Cause: Management of these programs was assigned about a year ago to the Administration and formal procedures have not been implemented yet. Effect: There were no internal control measures documented that allow the Administration to timely prevent and/or detect a noncompliance with the eligibility compliance requirement and avoid possible sanctions or restrictions in the use of funds by the federal awarding entity. Recommendation: We recommend that the Administration design and implement control activities procedures to achieve the objectives and respond to the risks associated with the eligibility requirement. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.
Finding number: 2022-002 Cluster: Housing Voucher Federal Programs: Assistance Listing 14.871 Section 8 Housing Choice Vouchers Category: Internal control ? control activities ? Special tests and provisions (waiting list, reasonable rent, housing quality standards inspection, HQS enforcement and housing assistance payment) Criteria or specific requirement: Title 2 2 CFR Part 200 Uniform Guidance section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal funds should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States (the Green Book) or the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations for the Treadway Commission (COSO). Condition: There were no formal written procedures outlining processes and control activities specific to the special tests and provisions applicable to the program. Questioned cost: No questioned costs were identified. Cause: Management of these programs was assigned about a year ago to the Administration and formal procedures have not been implemented yet. Effect: There were no internal control measures documented that guide the manager of the federal program to timely prevent and/or detect a noncompliance with the special tests and provisions applicable to the program. Recommendation: We recommend that the Administration document the control activities procedures to achieve the objectives and respond to the risks associated with the areas involved in the special tests and provisions of the Housing Voucher program. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.
SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding number: 2022-005 Federal Program: Housing Voucher Cluster - 14.871 Section 8 Housing Choice Vouchers Category: Compliance and Internal Control ? Eligibility Criteria or specific requirement: 24 CFR part 5, subpart F sections 5.601, 982.201, 982.515 and 982.516 determine whether income eligibility and calculate the tenant?s rent payment were made using the documentation from a third-party verification. Condition: In testing compliance with the eligibility requirements related to income-eligibility and tenant?s rent payment, we noticed the following from the sample of sixty (60) files: ? In one (1) instance the participant?s pay stubs used as evidence of the income determination were for salaries received in 2020 when it should have been salary stub for 2021. ? Two (2) of the files examined did not have the last certification of the Nutrition Assistance Program (PAN) used in form 50058 to document total annual family income. ? In one (1) of the files examined the annual income received by the participant and documented in form 50058 was not properly calculated since the computation was made on a monthly basis instead of a weekly basis as the income was actually received by the participant. Questioned cost: No questioned costs were identified. Perspective information: We selected sixty (60) files of new tenants during 2021-2022 fiscal year from the Section 8 waiting lists. Cause: The Administration?s review process of the eligibility documentation in the files was not effective in these cases. Effect: Any error in income calculation and with the evidence presented by the participants could lead to wrong eligibility determination. Recommendation: We recommend the Administration to reinforce their internal control procedures in the review of the eligibility determination to avoid similar situations in the future. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.
Finding number: 2022-004 Federal program: Assistance Listing 21.023 Emergency Assistance Program Category: Internal control ? Eligibility and Reporting Criteria or specific requirement: Title 2 2 CFR Part 200 Uniform Guidance section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal funds should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States (the Green Book) or the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations for the Treadway Commission (COSO). Condition: There was no evidence of formal written procedures to monitor the evaluation of the eligibility determination of participants neither was written evidence to ensure that the reporting to the federal awarding agency was complete and accurate. Questioned costs: No questioned costs were identified. Perspective information: We selected a sample of testing sixty (60) requests of participants for rental assistance out of 16,320 requests made for the year. Also, we selected the ERAP special reports for its corresponding reporting compliance for the three-quarter submitted during the year ended June 30, 2022. Cause: This Federal program was recently assigned to the Administration and formal procedures have not been implemented yet. Effect: There were no monitoring activities documented that allowed the Administration to timely prevent or detect a noncompliance with the requirements of eligibility and reporting. Recommendation: We recommend that the Administration design and implement written procedures to monitor the processes of eligibility determination and the completion of special reports. Views of responsible officials and planned corrective action: See Administration?s corrective action plan.