Audit 297906

2023 – 001 – Low Rent Public Housing Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Low Rent Public Housing Assistance Listing Number: 14.850 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 5, 902, 960, 966, and 990, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established an application and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that two files did not contain the completed Public Housing Annual Recertification checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-001 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003 – Housing Voucher Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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). (3) 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.) (24 CFR sections 982.201, 982.515, and 982.516). Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition: The Authority did not have sufficient internal controls over eligibility determinations to ensure compliance with HUD requirements.   Context: During our testing of 40 tenants for eligibility requirements, we noted the following: - 3 of 40 tenant files tested did not have a signed Declaration 214 for all members of the household - 11 of 40 tenant files tested did not have proper support for income - 6 of 40 tenant files tested did not have proper support for assets - 4 of 40 tenant files tested did not have proper support for expenses (deductions) - In total, 15 of 40 tenant files had improperly calculated rent due to missing and/or incorrect support for income, assets or expenses - 5 of 40 tenant files tested did not have a signed HUD-9886 in place - 11 of 40 tenant files tested did not have a HAP contract/HAP contract amendment on file - 2 of 40 tenant files tested had a HAP made on their behalf that did not match the HUD-50058 in effect Questioned costs: $45,541 Cause: The Authority has had vacancies and turnover in the staff who perform recertification processes, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD regulations over Eligibility, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their processes to ensure that the HAP calculated on the HUD-50058 is the amount paid to the landlords. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004 – Housing Voucher Cluster - HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Housing Quality Standards Inspections The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). HQS Enforcement For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAP's beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Authority did not have sufficient internal controls over Housing Quality Standards to ensure compliance with HUD requirements. Context: During our testing of 40 tenants for Annual HQS requirements, we noted the following: - 13 of 40 units tested did not have documentation of a completed HQS inspection within 24 months of the effective date. - 30 of 40 units tested did not have inspections performed on a biennial basis. - 10 of 40 tenants tested did not have an inspection report that was signed off as completed by the inspector. During our testing of 9 failed inspections, we noted 4 instances where abatement was not properly started and 2 instances where the Authority failed to enforce the family obligation in a timely manner. During our testing of 4 quality control (QC) re-inspections, we noted 2 instances where the QC inspection was not performed within 3 months of the original inspection. 1 file did not list the QC inspector’s name. 2 files had the same QC inspector for both the original inspection and the re-inspection. Questioned costs: $6,800 Cause: The staff performing the inspections did not properly use the Yardi software program available to conduct and document the inspection process. Additional training will be provided to staff. Effect: The Authority is not in compliance with HUD regulations regarding HQS inspections or HQS enforcement, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their inspection process to ensure that they are performed timely and that all documentation is maintained within Yardi. We recommend the Authority review their process for abatement/enforcing family obligations to ensure timely correction and enforcement. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005 – Housing Voucher Cluster - Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5% decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority did not have sufficient internal controls over reasonable rent determinations to ensure compliance with HUD requirements. Context: During our testing of 25 files for rent reasonableness requirements, we noted that 10 files had a reasonable rent determination that was not performed until after the effective date. Questioned costs: $1,800 Cause: The Authority has had turnover in the staff who perform the rent reasonableness determinations, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD’s requirements over rent reasonableness. Repeat Finding: No Recommendation: We recommend the Authority review their reasonable rent determination process to ensure that it is performed before the rent is set to go into effect. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006 – Housing Voucher Cluster – HUD-50058 PIC Submissions Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The PHA is required to submit the HUD-50058 electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908 and 24 CFR section 982.158). Condition: The Authority did not have sufficient internal controls over the PIC submission process to ensure compliance with HUD requirements. Context: During our testing of 40 recertifications we noted 1 that was not submitted electronically to HUD via the PIC system. Questioned costs: None Cause: The Public & Assisted Housing Compliance Analyst has had to assist property managers submit funding vouchers for other programs. This was an oversight and we will ensure all recertifications are submitted to HUD via the PIC system. Effect: The Authority is not in compliance with HUD’s regulations over reporting. Repeat Finding: No Recommendation: We recommend the Authority review their PIC upload process to ensure that all certifications are properly uploaded. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003 – Housing Voucher Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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). (3) 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.) (24 CFR sections 982.201, 982.515, and 982.516). Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition: The Authority did not have sufficient internal controls over eligibility determinations to ensure compliance with HUD requirements.   Context: During our testing of 40 tenants for eligibility requirements, we noted the following: - 3 of 40 tenant files tested did not have a signed Declaration 214 for all members of the household - 11 of 40 tenant files tested did not have proper support for income - 6 of 40 tenant files tested did not have proper support for assets - 4 of 40 tenant files tested did not have proper support for expenses (deductions) - In total, 15 of 40 tenant files had improperly calculated rent due to missing and/or incorrect support for income, assets or expenses - 5 of 40 tenant files tested did not have a signed HUD-9886 in place - 11 of 40 tenant files tested did not have a HAP contract/HAP contract amendment on file - 2 of 40 tenant files tested had a HAP made on their behalf that did not match the HUD-50058 in effect Questioned costs: $45,541 Cause: The Authority has had vacancies and turnover in the staff who perform recertification processes, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD regulations over Eligibility, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their processes to ensure that the HAP calculated on the HUD-50058 is the amount paid to the landlords. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004 – Housing Voucher Cluster - HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Housing Quality Standards Inspections The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). HQS Enforcement For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAP's beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Authority did not have sufficient internal controls over Housing Quality Standards to ensure compliance with HUD requirements. Context: During our testing of 40 tenants for Annual HQS requirements, we noted the following: - 13 of 40 units tested did not have documentation of a completed HQS inspection within 24 months of the effective date. - 30 of 40 units tested did not have inspections performed on a biennial basis. - 10 of 40 tenants tested did not have an inspection report that was signed off as completed by the inspector. During our testing of 9 failed inspections, we noted 4 instances where abatement was not properly started and 2 instances where the Authority failed to enforce the family obligation in a timely manner. During our testing of 4 quality control (QC) re-inspections, we noted 2 instances where the QC inspection was not performed within 3 months of the original inspection. 1 file did not list the QC inspector’s name. 2 files had the same QC inspector for both the original inspection and the re-inspection. Questioned costs: $6,800 Cause: The staff performing the inspections did not properly use the Yardi software program available to conduct and document the inspection process. Additional training will be provided to staff. Effect: The Authority is not in compliance with HUD regulations regarding HQS inspections or HQS enforcement, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their inspection process to ensure that they are performed timely and that all documentation is maintained within Yardi. We recommend the Authority review their process for abatement/enforcing family obligations to ensure timely correction and enforcement. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005 – Housing Voucher Cluster - Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5% decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority did not have sufficient internal controls over reasonable rent determinations to ensure compliance with HUD requirements. Context: During our testing of 25 files for rent reasonableness requirements, we noted that 10 files had a reasonable rent determination that was not performed until after the effective date. Questioned costs: $1,800 Cause: The Authority has had turnover in the staff who perform the rent reasonableness determinations, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD’s requirements over rent reasonableness. Repeat Finding: No Recommendation: We recommend the Authority review their reasonable rent determination process to ensure that it is performed before the rent is set to go into effect. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006 – Housing Voucher Cluster – HUD-50058 PIC Submissions Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The PHA is required to submit the HUD-50058 electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908 and 24 CFR section 982.158). Condition: The Authority did not have sufficient internal controls over the PIC submission process to ensure compliance with HUD requirements. Context: During our testing of 40 recertifications we noted 1 that was not submitted electronically to HUD via the PIC system. Questioned costs: None Cause: The Public & Assisted Housing Compliance Analyst has had to assist property managers submit funding vouchers for other programs. This was an oversight and we will ensure all recertifications are submitted to HUD via the PIC system. Effect: The Authority is not in compliance with HUD’s regulations over reporting. Repeat Finding: No Recommendation: We recommend the Authority review their PIC upload process to ensure that all certifications are properly uploaded. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003 – Housing Voucher Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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). (3) 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.) (24 CFR sections 982.201, 982.515, and 982.516). Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition: The Authority did not have sufficient internal controls over eligibility determinations to ensure compliance with HUD requirements.   Context: During our testing of 40 tenants for eligibility requirements, we noted the following: - 3 of 40 tenant files tested did not have a signed Declaration 214 for all members of the household - 11 of 40 tenant files tested did not have proper support for income - 6 of 40 tenant files tested did not have proper support for assets - 4 of 40 tenant files tested did not have proper support for expenses (deductions) - In total, 15 of 40 tenant files had improperly calculated rent due to missing and/or incorrect support for income, assets or expenses - 5 of 40 tenant files tested did not have a signed HUD-9886 in place - 11 of 40 tenant files tested did not have a HAP contract/HAP contract amendment on file - 2 of 40 tenant files tested had a HAP made on their behalf that did not match the HUD-50058 in effect Questioned costs: $45,541 Cause: The Authority has had vacancies and turnover in the staff who perform recertification processes, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD regulations over Eligibility, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their processes to ensure that the HAP calculated on the HUD-50058 is the amount paid to the landlords. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004 – Housing Voucher Cluster - HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Housing Quality Standards Inspections The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). HQS Enforcement For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAP's beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Authority did not have sufficient internal controls over Housing Quality Standards to ensure compliance with HUD requirements. Context: During our testing of 40 tenants for Annual HQS requirements, we noted the following: - 13 of 40 units tested did not have documentation of a completed HQS inspection within 24 months of the effective date. - 30 of 40 units tested did not have inspections performed on a biennial basis. - 10 of 40 tenants tested did not have an inspection report that was signed off as completed by the inspector. During our testing of 9 failed inspections, we noted 4 instances where abatement was not properly started and 2 instances where the Authority failed to enforce the family obligation in a timely manner. During our testing of 4 quality control (QC) re-inspections, we noted 2 instances where the QC inspection was not performed within 3 months of the original inspection. 1 file did not list the QC inspector’s name. 2 files had the same QC inspector for both the original inspection and the re-inspection. Questioned costs: $6,800 Cause: The staff performing the inspections did not properly use the Yardi software program available to conduct and document the inspection process. Additional training will be provided to staff. Effect: The Authority is not in compliance with HUD regulations regarding HQS inspections or HQS enforcement, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their inspection process to ensure that they are performed timely and that all documentation is maintained within Yardi. We recommend the Authority review their process for abatement/enforcing family obligations to ensure timely correction and enforcement. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005 – Housing Voucher Cluster - Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5% decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority did not have sufficient internal controls over reasonable rent determinations to ensure compliance with HUD requirements. Context: During our testing of 25 files for rent reasonableness requirements, we noted that 10 files had a reasonable rent determination that was not performed until after the effective date. Questioned costs: $1,800 Cause: The Authority has had turnover in the staff who perform the rent reasonableness determinations, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD’s requirements over rent reasonableness. Repeat Finding: No Recommendation: We recommend the Authority review their reasonable rent determination process to ensure that it is performed before the rent is set to go into effect. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006 – Housing Voucher Cluster – HUD-50058 PIC Submissions Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The PHA is required to submit the HUD-50058 electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908 and 24 CFR section 982.158). Condition: The Authority did not have sufficient internal controls over the PIC submission process to ensure compliance with HUD requirements. Context: During our testing of 40 recertifications we noted 1 that was not submitted electronically to HUD via the PIC system. Questioned costs: None Cause: The Public & Assisted Housing Compliance Analyst has had to assist property managers submit funding vouchers for other programs. This was an oversight and we will ensure all recertifications are submitted to HUD via the PIC system. Effect: The Authority is not in compliance with HUD’s regulations over reporting. Repeat Finding: No Recommendation: We recommend the Authority review their PIC upload process to ensure that all certifications are properly uploaded. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 001 – Low Rent Public Housing Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Low Rent Public Housing Assistance Listing Number: 14.850 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 5, 902, 960, 966, and 990, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established an application and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that two files did not contain the completed Public Housing Annual Recertification checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-001 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003 – Housing Voucher Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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). (3) 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.) (24 CFR sections 982.201, 982.515, and 982.516). Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition: The Authority did not have sufficient internal controls over eligibility determinations to ensure compliance with HUD requirements.   Context: During our testing of 40 tenants for eligibility requirements, we noted the following: - 3 of 40 tenant files tested did not have a signed Declaration 214 for all members of the household - 11 of 40 tenant files tested did not have proper support for income - 6 of 40 tenant files tested did not have proper support for assets - 4 of 40 tenant files tested did not have proper support for expenses (deductions) - In total, 15 of 40 tenant files had improperly calculated rent due to missing and/or incorrect support for income, assets or expenses - 5 of 40 tenant files tested did not have a signed HUD-9886 in place - 11 of 40 tenant files tested did not have a HAP contract/HAP contract amendment on file - 2 of 40 tenant files tested had a HAP made on their behalf that did not match the HUD-50058 in effect Questioned costs: $45,541 Cause: The Authority has had vacancies and turnover in the staff who perform recertification processes, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD regulations over Eligibility, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their processes to ensure that the HAP calculated on the HUD-50058 is the amount paid to the landlords. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004 – Housing Voucher Cluster - HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Housing Quality Standards Inspections The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). HQS Enforcement For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAP's beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Authority did not have sufficient internal controls over Housing Quality Standards to ensure compliance with HUD requirements. Context: During our testing of 40 tenants for Annual HQS requirements, we noted the following: - 13 of 40 units tested did not have documentation of a completed HQS inspection within 24 months of the effective date. - 30 of 40 units tested did not have inspections performed on a biennial basis. - 10 of 40 tenants tested did not have an inspection report that was signed off as completed by the inspector. During our testing of 9 failed inspections, we noted 4 instances where abatement was not properly started and 2 instances where the Authority failed to enforce the family obligation in a timely manner. During our testing of 4 quality control (QC) re-inspections, we noted 2 instances where the QC inspection was not performed within 3 months of the original inspection. 1 file did not list the QC inspector’s name. 2 files had the same QC inspector for both the original inspection and the re-inspection. Questioned costs: $6,800 Cause: The staff performing the inspections did not properly use the Yardi software program available to conduct and document the inspection process. Additional training will be provided to staff. Effect: The Authority is not in compliance with HUD regulations regarding HQS inspections or HQS enforcement, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their inspection process to ensure that they are performed timely and that all documentation is maintained within Yardi. We recommend the Authority review their process for abatement/enforcing family obligations to ensure timely correction and enforcement. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005 – Housing Voucher Cluster - Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5% decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority did not have sufficient internal controls over reasonable rent determinations to ensure compliance with HUD requirements. Context: During our testing of 25 files for rent reasonableness requirements, we noted that 10 files had a reasonable rent determination that was not performed until after the effective date. Questioned costs: $1,800 Cause: The Authority has had turnover in the staff who perform the rent reasonableness determinations, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD’s requirements over rent reasonableness. Repeat Finding: No Recommendation: We recommend the Authority review their reasonable rent determination process to ensure that it is performed before the rent is set to go into effect. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006 – Housing Voucher Cluster – HUD-50058 PIC Submissions Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The PHA is required to submit the HUD-50058 electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908 and 24 CFR section 982.158). Condition: The Authority did not have sufficient internal controls over the PIC submission process to ensure compliance with HUD requirements. Context: During our testing of 40 recertifications we noted 1 that was not submitted electronically to HUD via the PIC system. Questioned costs: None Cause: The Public & Assisted Housing Compliance Analyst has had to assist property managers submit funding vouchers for other programs. This was an oversight and we will ensure all recertifications are submitted to HUD via the PIC system. Effect: The Authority is not in compliance with HUD’s regulations over reporting. Repeat Finding: No Recommendation: We recommend the Authority review their PIC upload process to ensure that all certifications are properly uploaded. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003 – Housing Voucher Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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). (3) 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.) (24 CFR sections 982.201, 982.515, and 982.516). Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition: The Authority did not have sufficient internal controls over eligibility determinations to ensure compliance with HUD requirements.   Context: During our testing of 40 tenants for eligibility requirements, we noted the following: - 3 of 40 tenant files tested did not have a signed Declaration 214 for all members of the household - 11 of 40 tenant files tested did not have proper support for income - 6 of 40 tenant files tested did not have proper support for assets - 4 of 40 tenant files tested did not have proper support for expenses (deductions) - In total, 15 of 40 tenant files had improperly calculated rent due to missing and/or incorrect support for income, assets or expenses - 5 of 40 tenant files tested did not have a signed HUD-9886 in place - 11 of 40 tenant files tested did not have a HAP contract/HAP contract amendment on file - 2 of 40 tenant files tested had a HAP made on their behalf that did not match the HUD-50058 in effect Questioned costs: $45,541 Cause: The Authority has had vacancies and turnover in the staff who perform recertification processes, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD regulations over Eligibility, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their processes to ensure that the HAP calculated on the HUD-50058 is the amount paid to the landlords. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004 – Housing Voucher Cluster - HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Housing Quality Standards Inspections The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). HQS Enforcement For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAP's beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Authority did not have sufficient internal controls over Housing Quality Standards to ensure compliance with HUD requirements. Context: During our testing of 40 tenants for Annual HQS requirements, we noted the following: - 13 of 40 units tested did not have documentation of a completed HQS inspection within 24 months of the effective date. - 30 of 40 units tested did not have inspections performed on a biennial basis. - 10 of 40 tenants tested did not have an inspection report that was signed off as completed by the inspector. During our testing of 9 failed inspections, we noted 4 instances where abatement was not properly started and 2 instances where the Authority failed to enforce the family obligation in a timely manner. During our testing of 4 quality control (QC) re-inspections, we noted 2 instances where the QC inspection was not performed within 3 months of the original inspection. 1 file did not list the QC inspector’s name. 2 files had the same QC inspector for both the original inspection and the re-inspection. Questioned costs: $6,800 Cause: The staff performing the inspections did not properly use the Yardi software program available to conduct and document the inspection process. Additional training will be provided to staff. Effect: The Authority is not in compliance with HUD regulations regarding HQS inspections or HQS enforcement, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their inspection process to ensure that they are performed timely and that all documentation is maintained within Yardi. We recommend the Authority review their process for abatement/enforcing family obligations to ensure timely correction and enforcement. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005 – Housing Voucher Cluster - Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5% decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority did not have sufficient internal controls over reasonable rent determinations to ensure compliance with HUD requirements. Context: During our testing of 25 files for rent reasonableness requirements, we noted that 10 files had a reasonable rent determination that was not performed until after the effective date. Questioned costs: $1,800 Cause: The Authority has had turnover in the staff who perform the rent reasonableness determinations, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD’s requirements over rent reasonableness. Repeat Finding: No Recommendation: We recommend the Authority review their reasonable rent determination process to ensure that it is performed before the rent is set to go into effect. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006 – Housing Voucher Cluster – HUD-50058 PIC Submissions Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The PHA is required to submit the HUD-50058 electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908 and 24 CFR section 982.158). Condition: The Authority did not have sufficient internal controls over the PIC submission process to ensure compliance with HUD requirements. Context: During our testing of 40 recertifications we noted 1 that was not submitted electronically to HUD via the PIC system. Questioned costs: None Cause: The Public & Assisted Housing Compliance Analyst has had to assist property managers submit funding vouchers for other programs. This was an oversight and we will ensure all recertifications are submitted to HUD via the PIC system. Effect: The Authority is not in compliance with HUD’s regulations over reporting. Repeat Finding: No Recommendation: We recommend the Authority review their PIC upload process to ensure that all certifications are properly uploaded. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003 – Housing Voucher Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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). (3) 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.) (24 CFR sections 982.201, 982.515, and 982.516). Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). The PHA must pay a monthly HAP on behalf of the family that corresponds with the amount on line 12u of the HUD-50058. This HAP amount must be reflected on the HAP contract and HAP register (24 CFR section 982.158 and 24 CFR Part 982, Subpart K). Condition: The Authority did not have sufficient internal controls over eligibility determinations to ensure compliance with HUD requirements.   Context: During our testing of 40 tenants for eligibility requirements, we noted the following: - 3 of 40 tenant files tested did not have a signed Declaration 214 for all members of the household - 11 of 40 tenant files tested did not have proper support for income - 6 of 40 tenant files tested did not have proper support for assets - 4 of 40 tenant files tested did not have proper support for expenses (deductions) - In total, 15 of 40 tenant files had improperly calculated rent due to missing and/or incorrect support for income, assets or expenses - 5 of 40 tenant files tested did not have a signed HUD-9886 in place - 11 of 40 tenant files tested did not have a HAP contract/HAP contract amendment on file - 2 of 40 tenant files tested had a HAP made on their behalf that did not match the HUD-50058 in effect Questioned costs: $45,541 Cause: The Authority has had vacancies and turnover in the staff who perform recertification processes, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD regulations over Eligibility, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their processes to ensure that the HAP calculated on the HUD-50058 is the amount paid to the landlords. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004 – Housing Voucher Cluster - HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879/14.EHV Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Housing Quality Standards Inspections The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). HQS Enforcement For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAP's beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Authority did not have sufficient internal controls over Housing Quality Standards to ensure compliance with HUD requirements. Context: During our testing of 40 tenants for Annual HQS requirements, we noted the following: - 13 of 40 units tested did not have documentation of a completed HQS inspection within 24 months of the effective date. - 30 of 40 units tested did not have inspections performed on a biennial basis. - 10 of 40 tenants tested did not have an inspection report that was signed off as completed by the inspector. During our testing of 9 failed inspections, we noted 4 instances where abatement was not properly started and 2 instances where the Authority failed to enforce the family obligation in a timely manner. During our testing of 4 quality control (QC) re-inspections, we noted 2 instances where the QC inspection was not performed within 3 months of the original inspection. 1 file did not list the QC inspector’s name. 2 files had the same QC inspector for both the original inspection and the re-inspection. Questioned costs: $6,800 Cause: The staff performing the inspections did not properly use the Yardi software program available to conduct and document the inspection process. Additional training will be provided to staff. Effect: The Authority is not in compliance with HUD regulations regarding HQS inspections or HQS enforcement, which could have an impact on HAP calculations. Repeat Finding: No Recommendation: We recommend the Authority review their inspection process to ensure that they are performed timely and that all documentation is maintained within Yardi. We recommend the Authority review their process for abatement/enforcing family obligations to ensure timely correction and enforcement. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005 – Housing Voucher Cluster - Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner. The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5% decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: The Authority did not have sufficient internal controls over reasonable rent determinations to ensure compliance with HUD requirements. Context: During our testing of 25 files for rent reasonableness requirements, we noted that 10 files had a reasonable rent determination that was not performed until after the effective date. Questioned costs: $1,800 Cause: The Authority has had turnover in the staff who perform the rent reasonableness determinations, resulting in these processes being performed by less experienced and trained staff. Effect: The Authority is not in compliance with HUD’s requirements over rent reasonableness. Repeat Finding: No Recommendation: We recommend the Authority review their reasonable rent determination process to ensure that it is performed before the rent is set to go into effect. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006 – Housing Voucher Cluster – HUD-50058 PIC Submissions Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Federal Award Identification Number and Year: VA003, 2022-2023 Assistance Listing Number: 14.871/14.879/14.EHV Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The PHA is required to submit the HUD-50058 electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family (24 CFR Part 908 and 24 CFR section 982.158). Condition: The Authority did not have sufficient internal controls over the PIC submission process to ensure compliance with HUD requirements. Context: During our testing of 40 recertifications we noted 1 that was not submitted electronically to HUD via the PIC system. Questioned costs: None Cause: The Public & Assisted Housing Compliance Analyst has had to assist property managers submit funding vouchers for other programs. This was an oversight and we will ensure all recertifications are submitted to HUD via the PIC system. Effect: The Authority is not in compliance with HUD’s regulations over reporting. Repeat Finding: No Recommendation: We recommend the Authority review their PIC upload process to ensure that all certifications are properly uploaded. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002 – Section 8 Project-Based Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 8 Project-Based Cluster Assistance Listing Number: 14.249/14.182/14.195 Federal Award Identification Number and Year: VA003, 2022-2023 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with Title 24 of the Code of Federal Regulations parts 880 through 883, only eligible individuals should participate in the program and there should be evidence of eligibility determinations. The Authority has established a move-in and re-examination checklist to be used during the eligibility determination process to ensure that all required documents are maintained in the tenant’s file. Condition/Context: During our testing of five files for Eligibility requirements, we noted that one file did not contain the completed move-in or re-examination checklist. Questioned costs: None Cause: The Authority has had turnover in the staffing who perform eligibility determinations, resulting in eligibility determinations being performed by less experienced and trained staff. Effect: The Authority did not follow the internal controls designed to ensure compliance with Eligibility requirements. Repeat Finding: Yes, prior year finding 2022-002 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Views of responsible officials: There is no disagreement with the audit finding.