Audit 304564

FY End
2020-09-30
Total Expended
$6.56M
Findings
36
Programs
3
Year: 2020 Accepted: 2024-04-25

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
394650 2020-001 Material Weakness - N
394651 2020-002 Material Weakness - N
394652 2020-003 Material Weakness - N
394653 2020-004 Material Weakness - N
394654 2020-005 Material Weakness - N
394655 2020-006 Material Weakness - I
394656 2020-007 Material Weakness - I
394657 2020-008 Material Weakness - A
394658 2020-009 Material Weakness - A
394659 2020-010 Material Weakness - N
394660 2020-011 Material Weakness - N
394661 2020-012 Material Weakness - B
394662 2020-013 Material Weakness - N
394663 2020-014 Material Weakness - A
394664 2020-015 Material Weakness - B
394665 2020-016 Material Weakness - A
394666 2020-017 Material Weakness - N
394667 2020-018 Material Weakness - N
971092 2020-001 Material Weakness - N
971093 2020-002 Material Weakness - N
971094 2020-003 Material Weakness - N
971095 2020-004 Material Weakness - N
971096 2020-005 Material Weakness - N
971097 2020-006 Material Weakness - I
971098 2020-007 Material Weakness - I
971099 2020-008 Material Weakness - A
971100 2020-009 Material Weakness - A
971101 2020-010 Material Weakness - N
971102 2020-011 Material Weakness - N
971103 2020-012 Material Weakness - B
971104 2020-013 Material Weakness - N
971105 2020-014 Material Weakness - A
971106 2020-015 Material Weakness - B
971107 2020-016 Material Weakness - A
971108 2020-017 Material Weakness - N
971109 2020-018 Material Weakness - N

Programs

ALN Program Spent Major Findings
14.872 Public Housing Capital Fund $2.89M Yes 3
14.850 Public and Indian Housing $81,392 - 0
14.871 Section 8 Housing Choice Vouchers $20,347 - 0

Contacts

Name Title Type
H2X6UC5FSCT5 Derrek Sherburne Auditee
4795213850 Louis Barrale Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: NOTE 1 - Basis of Presentation The Schedule of Expenditures of Federal Awards (the Schedule) presents the activity of all Federal award programs of the Authority. All Federal awards received directly from Federal agencies as well as Federal awards passed through other governmental agencies or other entities are included in the Schedule. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200. Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) Because the Schedule presents only a select position, changes in net position or cash flows of the Authority. NOTE 2 - Significant Accounting Policies The Authority’s Schedule of Federal Awards has been prepared on the accrual basis of accounting. Grant revenue is recognized on the modified accrual bases and, when all applicable eligibility requirements are met in accordance with the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The criteria established by GASB for accrual-bases recognition require that all eligibility requirements must be met, and the revenues must be available. “Available” means that the government has collected the revenues in the current period or expects to collect them soon enough after the end of the period to use them to pay liabilities of the current period. Resources received or recognized as receivables before the time requirements are met are reported as deferred revenues. The Authority has elected not to use the 10-percent de minims indirect cost rate allowed under the Uniform Guidance. NOTE 3 - Contingencies In connection with various Federal grant programs the Authority is obligated to administer related programs and spend the funds in accordance with regulatory restrictions and is subject to audit by grantor agencies and other auditors. In cases of noncompliance, the agencies involved may require the Authority to refund program funds. De Minimis Rate Used: N Rate Explanation: The Housing Authority has elected not to use the 10-percent de minims indirect cost rate allowed under the Uniform Guidance. The Schedule of Expenditures of Federal Awards (the Schedule) presents the activity of all Federal award programs of the Authority. All Federal awards received directly from Federal agencies as well as Federal awards passed through other governmental agencies or other entities are included in the Schedule. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200. Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) Because the Schedule presents only a select position, changes in net position or cash flows of the Authority.
Title: Significant Accounting Policies Accounting Policies: NOTE 1 - Basis of Presentation The Schedule of Expenditures of Federal Awards (the Schedule) presents the activity of all Federal award programs of the Authority. All Federal awards received directly from Federal agencies as well as Federal awards passed through other governmental agencies or other entities are included in the Schedule. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200. Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) Because the Schedule presents only a select position, changes in net position or cash flows of the Authority. NOTE 2 - Significant Accounting Policies The Authority’s Schedule of Federal Awards has been prepared on the accrual basis of accounting. Grant revenue is recognized on the modified accrual bases and, when all applicable eligibility requirements are met in accordance with the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The criteria established by GASB for accrual-bases recognition require that all eligibility requirements must be met, and the revenues must be available. “Available” means that the government has collected the revenues in the current period or expects to collect them soon enough after the end of the period to use them to pay liabilities of the current period. Resources received or recognized as receivables before the time requirements are met are reported as deferred revenues. The Authority has elected not to use the 10-percent de minims indirect cost rate allowed under the Uniform Guidance. NOTE 3 - Contingencies In connection with various Federal grant programs the Authority is obligated to administer related programs and spend the funds in accordance with regulatory restrictions and is subject to audit by grantor agencies and other auditors. In cases of noncompliance, the agencies involved may require the Authority to refund program funds. De Minimis Rate Used: N Rate Explanation: The Housing Authority has elected not to use the 10-percent de minims indirect cost rate allowed under the Uniform Guidance. The Authority’s Schedule of Federal Awards has been prepared on the accrual basis of accounting. Grant revenue is recognized on the modified accrual bases and, when all applicable eligibility requirements are met in accordance with the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The criteria established by GASB for accrual-bases recognition require that all eligibility requirements must be met, and the revenues must be available. “Available” means that the government has collected the revenues in the current period or expects to collect them soon enough after the end of the period to use them to pay liabilities of the current period. Resources received or recognized as receivables before the time requirements are met are reported as deferred revenues. The Authority has elected not to use the 10-percent de minims indirect cost rate allowed under the Uniform Guidance.
Title: Contingencies Accounting Policies: NOTE 1 - Basis of Presentation The Schedule of Expenditures of Federal Awards (the Schedule) presents the activity of all Federal award programs of the Authority. All Federal awards received directly from Federal agencies as well as Federal awards passed through other governmental agencies or other entities are included in the Schedule. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200. Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) Because the Schedule presents only a select position, changes in net position or cash flows of the Authority. NOTE 2 - Significant Accounting Policies The Authority’s Schedule of Federal Awards has been prepared on the accrual basis of accounting. Grant revenue is recognized on the modified accrual bases and, when all applicable eligibility requirements are met in accordance with the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The criteria established by GASB for accrual-bases recognition require that all eligibility requirements must be met, and the revenues must be available. “Available” means that the government has collected the revenues in the current period or expects to collect them soon enough after the end of the period to use them to pay liabilities of the current period. Resources received or recognized as receivables before the time requirements are met are reported as deferred revenues. The Authority has elected not to use the 10-percent de minims indirect cost rate allowed under the Uniform Guidance. NOTE 3 - Contingencies In connection with various Federal grant programs the Authority is obligated to administer related programs and spend the funds in accordance with regulatory restrictions and is subject to audit by grantor agencies and other auditors. In cases of noncompliance, the agencies involved may require the Authority to refund program funds. De Minimis Rate Used: N Rate Explanation: The Housing Authority has elected not to use the 10-percent de minims indirect cost rate allowed under the Uniform Guidance. In connection with various Federal grant programs the Authority is obligated to administer related programs and spend the funds in accordance with regulatory restrictions and is subject to audit by grantor agencies and other auditors. In cases of noncompliance, the agencies involved may require the Authority to refund program funds

Finding Details

2020-001 Tenant Files - Annual Certifications Were Not Done Criteria: Under the terms of the Public Housing Occupancy Guide ~ Complete the reexamination within a year (12 months) of the previous annual reexamination or new admission for families paying income-based rent. Any Housing Authority not in compliance with annual income reexamination requirements at the time of the submission of the calculation of operating subsidy shall furnish to the responsible HUD field office a copy of the procedures it is using to achieve compliance and a statement of the number of families that have undergone reexamination during the 12 months preceding the current funding cycle. If, on the basis of this submission or any other information, HUD determines that the Housing Authority is not substantially in compliance with all of the annual income reexamination requirements, HUD shall withhold payments to which the Housing Authority may be entitled under this part. Payment may be withheld in an amount equal to HUD's estimate of the loss of rental income to the Housing Authority resulting from its failure to comply with the requirements. Condition: We noted some tenant files were not recertified, after the tenant moved into the Housing Authority property. Questioned Costs: Cannot be determined, due to incomplete information. Effect: Tenant rent and subsidy calculations are incorrect and not up to date. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs review all tenant files and recertify all tenant files annually. We recommend the Fayetteville Housing Authority implement a schedule to ensure that tenant recertifications are completed annually.
2020-002 Tenant Files - Annual Certifications Were Not Completed in a Timely Manner Criteria: Under the terms of the Public Housing Occupancy Guide ~ Complete the reexamination within a year (12 months) of the previous annual reexamination or new admission for families paying income-based rent. Any Housing Authority not in compliance with annual income reexamination requirements at the time of the submission of the calculation of operating subsidy shall furnish to the responsible HUD field office a copy of the procedures it is using to achieve compliance and a statement of the number of families that have undergone reexamination during the 12 months preceding the current funding cycle. If, on the basis of this submission or any other information, HUD determines that the Housing Authority is not substantially in compliance with all of the annual income reexamination requirements, HUD shall withhold payments to which the Housing Authority may be entitled under this part. Payment may be withheld in an amount equal to HUD's estimate of the loss of rental income to the Housing Authority resulting from its failure to comply with the requirements. Condition: We noted tenant files were recertified after the deadline for recertification and well after the twelve-month deadline for recertifications. Questioned Costs: Cannot be determined, due to incomplete information. Effect: Tenant rent and subsidy calculations are incorrect and not up to date. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs review all tenant files and recertify all tenant files in a timely manner. We recommend the Fayetteville Housing Authority implement a schedule to ensure that tenant recertifications are completed annually and on time.
2020-003 Tenant Files - Third Party Income Verification Was Not Performed Criteria: Under the terms of the Public Housing Occupancy Guide ~ The EIV System is a web-based application, which provides PHAs with employment, wage, unemployment compensation and social security benefit information for tenants who participate in the Public Housing and various Section 8 programs. PHAs must use the EIV system in its entirety to verify tenant employment and income information during interim and mandatory reexaminations of family composition and income in accordance with 24 CFR §§ 5.233, 5.236, and other HUD administrative guidance. Condition: We noted that tenant files were missing the EIV system income verification for the tenant’s income. Questioned Costs: Cannot be determined, due to incomplete information. Effect: Tenant rent and subsidy calculations could be incorrect due to possible incorrect income being reported by the tenant. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs to review all tenant files to ensure that tenant income has been verified in the EIV system and verification is documented.
2020-004 Tenant Files - Missing Documentation Criteria: Under the terms of the Annual Contribution Contract, PHAs must maintain a file for each program applicant/participant. Files may be maintained in paper or electronic format. These files are subject to audit and review by HUD, or Independent Public Accountants (IPAs), or HUD’s designee upon proper notification to the Housing Authority. The file should include (but is not limited to): housing application and supporting documents, income executed lease(s), unit inspection reports, verifications, leases, supplements to lease, notices and letters, income and rent determinations and a summary of Housing Authority interactions with the tenant. The Housing Authority must maintain these files in an area that is secure and private. The Housing Authority must also have record retention and destruction policies. Condition: We noted that tenant files were missing some, if not all, of the document required by HUD for its tenant files. Questioned Costs: Cannot be determined, due to incomplete information. Effect: Tenant files are incomplete. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs to review all tenant files and ensure that tenant files contain all required HUD documentation. We also recommend that the Fayetteville Housing Authority set up a system to ensure that all required documentation in included in the tenant file for each recertification of the tenant.
2020-005 Tenant Files - Rental Lease Does Not Agree with Rental Register Criteria: The Housing Authority’s rental register and rents collected, should match the rents on the signed lease and HUD 50058 for tenant portion of rent. Condition: The rents shown on the Fayetteville Housing Authority’s rental register did not match the tenant portion of rents shown in the tenant files. Questioned Costs: Cannot be determined, due to incomplete information. Effect: The Fayetteville Housing Authority is collecting incorrect rent from its tenants. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs to review all tenant files and compare the tenant portion of rent listed to the rental register and adjust the rental register to reflect the correct rents and notify the tenant of their correct rents.
2020-006 HUD Procurement Policies Were Not Followed Criteria: In accordance with HUD Procurement policies, competitive proposals are used to purchase professional services where the total cost will exceed $100,000. The grantee must solicit proposals from an adequate number of qualified sources. Condition: We noted on several instances that the Fayetteville Housing Authority solicited proposal from a single contractor for services over the $100,000. Questioned Costs: In excess of $3.5 million dollars. Effect: The Fayetteville Housing Authority did not ensure that Federal funds were expended in most efficient and economical way. Cause: Lack of management oversight. Recommendation: We recommend that the Fayetteville Housing Authority do advance planning to provide the Fayetteville Housing Authority with adequate time to accomplish its procurement actions. The Fayetteville Housing Authority should periodically review its records of prior purchases, as well as future needs, to find patterns of procurement actions that could be performed more efficiently or economically.
2020-007 Incomplete Contract Files Criteria In accordance with HUD Procurement Policy ~ General 24 (CFR 85.36(b)(9)). The Housing Authority must maintain records sufficient to detail the significant history of each procurement action. Such documentation is particularly important in the event a protest is lodged against the Housing Authority. It will also facilitate future purchases of similar supplies or services since it will not be necessary to recreate solicitation documents. Supporting documentation shall be in writing and placed in the procurement file. Conditions: We noted that contract files were incomplete and missing significant documentation related to the contract. Questioned Costs: In excess of $3.5 million dollars. Effect: With incomplete contract files, it is difficult to verify the progress and expenditures related to the contracts the Fayetteville Housing Authority has entered into. Cause: Lack of Management oversight Recommendation: We recommend that the Fayetteville Housing Authority review all contract files and ensure they have complete documentation of the contract, expenditures related to that contract and progress reports. We also recommend that going forward contract files be kept in accordance to HUD procurement polies.
2020-008 Misappropriation of Capital Fund Reserve for Emergencies and Natural Disasters Criteria: Housing Authorities are permitted to expend federal funds in accordance with the agreements stated forth in the awards and not for any other purpose. Condition: On September 1, 2017, the Fayetteville Housing Authority requested emergency funding from the Capital Fund Reserve for Emergencies and Natural Disaster Funds for the replacement of HVAC piping, domestic water piping and sewer line piping at the Fayetteville Housing Authority’s Hillcrest Towers, in the amount of $3,810,271. The Fayetteville Housing Authority had two years to fully expend the grant. Fayetteville Housing Authority may not use this funding for any other purpose other then the replacement of HVAC piping, domestic water piping and sewer line piping at Hillcrest Towers. Fayetteville Housing Authority may not use this funding to pay for deferred maintenance or the cost of operations. The Fayetteville Housing Authority used some of the funding designated for HVAC piping, domestic water piping and sewer line piping for relocation costs, food allowances and other Fayetteville Housing Authority expenses for Fayetteville Housing Authority tenants misplaced by the repairs taking place at Hillcrest Towers. Questioned Costs: Cannot be determined, due to incomplete information. Effect: The Fayetteville Housing Authority misused federal funding Cause: Lack of Management oversight Recommendation: We recommend the Fayetteville Housing Authority review all expenditures related to the Emergency Grant and ensure that those expenditures were only for the replacement of HVAC piping, domestic water piping and sewer line piping. If expenditures are not related to the replacement of piping, the Fayetteville Housing Authority should make arrangement to repay those funds to the funding agency.
2020-009 Food Allowances Paid in Excess of Allowable Amounts and From Improper Funds Criteria: Project-specific operating expenses include, but are not limited to, direct administrative costs, utilities costs, maintenance costs, tenant services, (Housing Authorities are permitted to fund $25 per unit per year for units represented by duly elected resident councils for resident services.) protective services, general expenses, non-routine or capital expenses, and other Housing Authority- or HUD-identified costs which are project-specific for management purposes. Condition: We noted that between October 2019 and May 2020, the Fayetteville Housing Authority paid 14 tenants a food allowance between $325 and $350 a month out of the Emergency Grant. Furthermore, these food allowances were not approved by the Board of Commissioners. Questioned Costs: $38,000 Effect: The Housing Authority expended funds on unauthorized expenditures. Cause: Lack of Management oversight Recommendation: We recommend the Fayetteville Housing Authority review all expenditures related to the Emergency Grant and ensure that those expenditures were only for the replacement of HVAC piping, domestic water piping and sewer line piping. If expenditures not related to the replacement of piping, the Fayetteville Housing Authority should make arrangement to repay those funds to the funding agency.
2020-010 Missing Documentation - Invoices for Accounts Payable Purchases Criteria: Accurate record keeping and reporting are crucial to the successful management of Housing Authority funded activities. The Housing Authority is charged with maintaining source documents and files that support the financial transactions recorded in the books, providing an adequate audit trail. Condition: The Fayetteville Housing Authority was unable to produce requested documents and receipts supporting Fayetteville Housing Authority expenditures. Questioned Costs: Cannot be determined, due to incomplete information. Effect: The Fayetteville Housing Authority’s expenditures were not supported. Cause: Lack of Management oversight Recommendation: We recommend the Fayetteville Housing Authority implement a system to maintain source documents and files that support the financial transactions.
2020-011 Missing Documentation - Davis-Bacon Certified Payroll Reports Criteria: Requested information should be readily available for audit examination. The Housing Authority is responsible for the proper administration and enforcement of the Federal labor standards provisions on contracts covered by Davis-Bacon requirements, and therefore must maintain all Davis-Bacon certified payroll reports (OMB No. 1235-0008) for the entire length of the contract. Condition: The Fayetteville Housing Authority was unable to locate all of the weekly Davis-Bacon certified payroll reports related to the Emergency Grant. Questioned Costs: Undetermined due to missing documentation. Effect: We are unable to determine that all laborers were paid the prevailing wage rate, as determined by the United States Department of Labor. Cause: Lack of Management oversight. Recommendation: We recommend the Fayetteville Housing Authority’s management place a greater emphasis in safe keeping its records and ensuring that all information requested is readily available for audit examination. We also recommend that the Fayetteville Housing Authority monitor labor standard compliance by conducting interviews with construction workers at the job site, reviews payroll reports, and oversees any additional enforcement actions that may be required.
2020-012 Missing Documentation - Receipts for Credit Card Purchases Criteria: Requested information should be readily available for audit examination. Condition: The Fayetteville Housing Authority was unable to locate some receipts to credit card purchases for audit examination. Questioned Costs: Undetermined due to missing documentation. Effect: We are unable to determine the accuracy of the financial statement amounts due to lack of supporting documentation. Cause: The Fayetteville Housing Authority did not secure all the required receipts for supporting documentation. Recommendation: We recommend the Fayetteville Housing Authority’s management place a greater emphasis in safe keeping its records to ensure all receipts for every transaction is accounted for.
2020-013 Internal Controls Were Not Followed Criteria: Invoices for accounts payables should be properly authorized for payment prior to entry into the computer software. Condition: Invoices for accounts payables were not properly authorized by Fayetteville Housing Authority management. Questioned Costs: Unknown. Effect: No clear document trail on disbursements. Cause: The Fayetteville Housing Authority did not place emphasis on ensuring that the invoices paid were being reviewed and authorized. Recommendation: We recommend that the Fayetteville Housing Authority ensure that all invoices are adequately initialed or signed to ensure that they are correct and authorized.
2020-014 Misappropriation of Federal Funds - Cell Phone Tower Criteria: Housing Authorities are permitted to use federal funds and funds derived from federal sources for approved activities only. Condition: The Fayetteville Housing Authority issued a forgivable loan to FHA Development, Inc. in the amount of $18,000.00 from monies received in rent from a cell phone tower that is located on top of the high-rise building, which is considered Federal property. We noted a Board Resolution (#1194) stating that the monies received from the rental of the top of the high-rise building to be considered non-federal money. Questioned Costs: $18,000.00 Effect: Because the cell phone tower sits atop the Hillcrest Tower building, which is part of the Fayetteville Housing Authority property, any income derived from this source is considered to be federal money. Cause: Lack of oversight by Fayetteville Housing Authority management. Recommendation: We recommend that the Fayetteville Housing Authority requires FHA Development, Inc. to immediately repay to the Fayetteville Housing Authority the $18,000.00 in federal money that was misappropriated.
2020-015 Misappropriation of Federal Funds - Improper Receivable Criteria: A Housing Authority is required to maintain a repayment plan with a component unit for any costs incurred by the Housing Authority on behalf of the component unit. Condition: The Fayetteville Housing Authority has an accounts receivable balance in the amount of $107,360.56 which represents costs incurred by the FHA Development, Inc. but paid by the Fayetteville Housing Authority. Questioned Costs: $107,360.56 Effect: Federal money received by the Fayetteville Housing Authority from the federal sources was misappropriated to subsidize the operations of the FHA Development, Inc.. Cause: Lack of oversight by Housing Authority management. Recommendation: We recommend that the Fayetteville Housing Authority requires the FHA Development, Inc. to immediately repay to the Fayetteville Housing Authority the $107,360.56 in federal money that was misappropriated.
2020-016 Misappropriation of Federal Funds - Improper Allocation of Housing Authority Funds and Staff Criteria: A Housing Authority is required to maintain a cost sharing agreement with a component unit for any costs incurred by the Housing Authority on behalf of the component unit. Condition: The Fayetteville Housing Authority has incurred direct costs on behalf of the FHA Development, Inc. Furthermore, it was observed at the time of our audit that Fayetteville Housing Authority maintenance staff were performing work on the FHA Development, Inc. properties. Questioned Costs: Unknown Effect: Federal money received by the Fayetteville Housing Authority from the federal sources was misappropriated to subsidize the operations of the FHA Development, Inc. Cause: Lack of oversight by Fayetteville Housing Authority management. Recommendation: We recommend that the Fayetteville Housing Authority discontinue incurring expenses on behalf of the FHA Development, Inc. and discontinue utilizing Fayetteville Housing Authority staff time on the FHA Development, Inc. properties until the proper cost sharing agreement is in place.
2020-017 Misstatements in Financial Statements Criteria: A Housing Authority is required to prepare accurate financial statements free from material misstatement. Condition: The financial statements for the Fayetteville Housing Authority contain the following misstatements: The financial activity for the FHA Development, Inc. was included in the Business Activities Project in the FDS submission and in detail accounts of the general ledger. The FHA Development, Inc. Company, Inc. is a 501(3)(c) Not for Profit Corporation and as such, should be presented on the financial statements as a discretely presented component unit. The current accounting and presentation obscure the activity of the FHA Development, Inc. by imbedding it within the financial statements of the Fayetteville Housing Authority, which is misleading. Questioned Costs: Unknown Effect: The financial statements of the Fayetteville Housing Authority are misstated. Cause: Fayetteville Housing Authority management did not properly prepare and submit their unaudited financial statement submission to HUD Recommendation: We recommend that the Fayetteville Housing Authority properly prepare their financial statements to present the FHA Development, Inc. as a discretely presented component unit.
2020-018 Unresponsive Attorney Criteria: An attorney for a Housing Authority is required to respond to auditor inquiries on behalf of the Housing Authority. Condition: During our audit we requested a description of any and all material pending or threatened litigation, claims and assessments (excluding unasserted claims and assessments). Questioned Costs: Unknown Effect: The Fayetteville Housing Authority may be subject to pending or actual litigation which should be disclosed in the notes to the financial statements. Cause: Fayetteville Housing Authority management did not ensure a response from their attorney. Recommendation: We recommend that the Fayetteville Housing Authority properly obtain the requested response from its attorney.
2020-001 Tenant Files - Annual Certifications Were Not Done Criteria: Under the terms of the Public Housing Occupancy Guide ~ Complete the reexamination within a year (12 months) of the previous annual reexamination or new admission for families paying income-based rent. Any Housing Authority not in compliance with annual income reexamination requirements at the time of the submission of the calculation of operating subsidy shall furnish to the responsible HUD field office a copy of the procedures it is using to achieve compliance and a statement of the number of families that have undergone reexamination during the 12 months preceding the current funding cycle. If, on the basis of this submission or any other information, HUD determines that the Housing Authority is not substantially in compliance with all of the annual income reexamination requirements, HUD shall withhold payments to which the Housing Authority may be entitled under this part. Payment may be withheld in an amount equal to HUD's estimate of the loss of rental income to the Housing Authority resulting from its failure to comply with the requirements. Condition: We noted some tenant files were not recertified, after the tenant moved into the Housing Authority property. Questioned Costs: Cannot be determined, due to incomplete information. Effect: Tenant rent and subsidy calculations are incorrect and not up to date. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs review all tenant files and recertify all tenant files annually. We recommend the Fayetteville Housing Authority implement a schedule to ensure that tenant recertifications are completed annually.
2020-002 Tenant Files - Annual Certifications Were Not Completed in a Timely Manner Criteria: Under the terms of the Public Housing Occupancy Guide ~ Complete the reexamination within a year (12 months) of the previous annual reexamination or new admission for families paying income-based rent. Any Housing Authority not in compliance with annual income reexamination requirements at the time of the submission of the calculation of operating subsidy shall furnish to the responsible HUD field office a copy of the procedures it is using to achieve compliance and a statement of the number of families that have undergone reexamination during the 12 months preceding the current funding cycle. If, on the basis of this submission or any other information, HUD determines that the Housing Authority is not substantially in compliance with all of the annual income reexamination requirements, HUD shall withhold payments to which the Housing Authority may be entitled under this part. Payment may be withheld in an amount equal to HUD's estimate of the loss of rental income to the Housing Authority resulting from its failure to comply with the requirements. Condition: We noted tenant files were recertified after the deadline for recertification and well after the twelve-month deadline for recertifications. Questioned Costs: Cannot be determined, due to incomplete information. Effect: Tenant rent and subsidy calculations are incorrect and not up to date. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs review all tenant files and recertify all tenant files in a timely manner. We recommend the Fayetteville Housing Authority implement a schedule to ensure that tenant recertifications are completed annually and on time.
2020-003 Tenant Files - Third Party Income Verification Was Not Performed Criteria: Under the terms of the Public Housing Occupancy Guide ~ The EIV System is a web-based application, which provides PHAs with employment, wage, unemployment compensation and social security benefit information for tenants who participate in the Public Housing and various Section 8 programs. PHAs must use the EIV system in its entirety to verify tenant employment and income information during interim and mandatory reexaminations of family composition and income in accordance with 24 CFR §§ 5.233, 5.236, and other HUD administrative guidance. Condition: We noted that tenant files were missing the EIV system income verification for the tenant’s income. Questioned Costs: Cannot be determined, due to incomplete information. Effect: Tenant rent and subsidy calculations could be incorrect due to possible incorrect income being reported by the tenant. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs to review all tenant files to ensure that tenant income has been verified in the EIV system and verification is documented.
2020-004 Tenant Files - Missing Documentation Criteria: Under the terms of the Annual Contribution Contract, PHAs must maintain a file for each program applicant/participant. Files may be maintained in paper or electronic format. These files are subject to audit and review by HUD, or Independent Public Accountants (IPAs), or HUD’s designee upon proper notification to the Housing Authority. The file should include (but is not limited to): housing application and supporting documents, income executed lease(s), unit inspection reports, verifications, leases, supplements to lease, notices and letters, income and rent determinations and a summary of Housing Authority interactions with the tenant. The Housing Authority must maintain these files in an area that is secure and private. The Housing Authority must also have record retention and destruction policies. Condition: We noted that tenant files were missing some, if not all, of the document required by HUD for its tenant files. Questioned Costs: Cannot be determined, due to incomplete information. Effect: Tenant files are incomplete. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs to review all tenant files and ensure that tenant files contain all required HUD documentation. We also recommend that the Fayetteville Housing Authority set up a system to ensure that all required documentation in included in the tenant file for each recertification of the tenant.
2020-005 Tenant Files - Rental Lease Does Not Agree with Rental Register Criteria: The Housing Authority’s rental register and rents collected, should match the rents on the signed lease and HUD 50058 for tenant portion of rent. Condition: The rents shown on the Fayetteville Housing Authority’s rental register did not match the tenant portion of rents shown in the tenant files. Questioned Costs: Cannot be determined, due to incomplete information. Effect: The Fayetteville Housing Authority is collecting incorrect rent from its tenants. Cause: Lack of oversight by Fayetteville Housing Authority Management. Recommendation: The Fayetteville Housing Authority needs to review all tenant files and compare the tenant portion of rent listed to the rental register and adjust the rental register to reflect the correct rents and notify the tenant of their correct rents.
2020-006 HUD Procurement Policies Were Not Followed Criteria: In accordance with HUD Procurement policies, competitive proposals are used to purchase professional services where the total cost will exceed $100,000. The grantee must solicit proposals from an adequate number of qualified sources. Condition: We noted on several instances that the Fayetteville Housing Authority solicited proposal from a single contractor for services over the $100,000. Questioned Costs: In excess of $3.5 million dollars. Effect: The Fayetteville Housing Authority did not ensure that Federal funds were expended in most efficient and economical way. Cause: Lack of management oversight. Recommendation: We recommend that the Fayetteville Housing Authority do advance planning to provide the Fayetteville Housing Authority with adequate time to accomplish its procurement actions. The Fayetteville Housing Authority should periodically review its records of prior purchases, as well as future needs, to find patterns of procurement actions that could be performed more efficiently or economically.
2020-007 Incomplete Contract Files Criteria In accordance with HUD Procurement Policy ~ General 24 (CFR 85.36(b)(9)). The Housing Authority must maintain records sufficient to detail the significant history of each procurement action. Such documentation is particularly important in the event a protest is lodged against the Housing Authority. It will also facilitate future purchases of similar supplies or services since it will not be necessary to recreate solicitation documents. Supporting documentation shall be in writing and placed in the procurement file. Conditions: We noted that contract files were incomplete and missing significant documentation related to the contract. Questioned Costs: In excess of $3.5 million dollars. Effect: With incomplete contract files, it is difficult to verify the progress and expenditures related to the contracts the Fayetteville Housing Authority has entered into. Cause: Lack of Management oversight Recommendation: We recommend that the Fayetteville Housing Authority review all contract files and ensure they have complete documentation of the contract, expenditures related to that contract and progress reports. We also recommend that going forward contract files be kept in accordance to HUD procurement polies.
2020-008 Misappropriation of Capital Fund Reserve for Emergencies and Natural Disasters Criteria: Housing Authorities are permitted to expend federal funds in accordance with the agreements stated forth in the awards and not for any other purpose. Condition: On September 1, 2017, the Fayetteville Housing Authority requested emergency funding from the Capital Fund Reserve for Emergencies and Natural Disaster Funds for the replacement of HVAC piping, domestic water piping and sewer line piping at the Fayetteville Housing Authority’s Hillcrest Towers, in the amount of $3,810,271. The Fayetteville Housing Authority had two years to fully expend the grant. Fayetteville Housing Authority may not use this funding for any other purpose other then the replacement of HVAC piping, domestic water piping and sewer line piping at Hillcrest Towers. Fayetteville Housing Authority may not use this funding to pay for deferred maintenance or the cost of operations. The Fayetteville Housing Authority used some of the funding designated for HVAC piping, domestic water piping and sewer line piping for relocation costs, food allowances and other Fayetteville Housing Authority expenses for Fayetteville Housing Authority tenants misplaced by the repairs taking place at Hillcrest Towers. Questioned Costs: Cannot be determined, due to incomplete information. Effect: The Fayetteville Housing Authority misused federal funding Cause: Lack of Management oversight Recommendation: We recommend the Fayetteville Housing Authority review all expenditures related to the Emergency Grant and ensure that those expenditures were only for the replacement of HVAC piping, domestic water piping and sewer line piping. If expenditures are not related to the replacement of piping, the Fayetteville Housing Authority should make arrangement to repay those funds to the funding agency.
2020-009 Food Allowances Paid in Excess of Allowable Amounts and From Improper Funds Criteria: Project-specific operating expenses include, but are not limited to, direct administrative costs, utilities costs, maintenance costs, tenant services, (Housing Authorities are permitted to fund $25 per unit per year for units represented by duly elected resident councils for resident services.) protective services, general expenses, non-routine or capital expenses, and other Housing Authority- or HUD-identified costs which are project-specific for management purposes. Condition: We noted that between October 2019 and May 2020, the Fayetteville Housing Authority paid 14 tenants a food allowance between $325 and $350 a month out of the Emergency Grant. Furthermore, these food allowances were not approved by the Board of Commissioners. Questioned Costs: $38,000 Effect: The Housing Authority expended funds on unauthorized expenditures. Cause: Lack of Management oversight Recommendation: We recommend the Fayetteville Housing Authority review all expenditures related to the Emergency Grant and ensure that those expenditures were only for the replacement of HVAC piping, domestic water piping and sewer line piping. If expenditures not related to the replacement of piping, the Fayetteville Housing Authority should make arrangement to repay those funds to the funding agency.
2020-010 Missing Documentation - Invoices for Accounts Payable Purchases Criteria: Accurate record keeping and reporting are crucial to the successful management of Housing Authority funded activities. The Housing Authority is charged with maintaining source documents and files that support the financial transactions recorded in the books, providing an adequate audit trail. Condition: The Fayetteville Housing Authority was unable to produce requested documents and receipts supporting Fayetteville Housing Authority expenditures. Questioned Costs: Cannot be determined, due to incomplete information. Effect: The Fayetteville Housing Authority’s expenditures were not supported. Cause: Lack of Management oversight Recommendation: We recommend the Fayetteville Housing Authority implement a system to maintain source documents and files that support the financial transactions.
2020-011 Missing Documentation - Davis-Bacon Certified Payroll Reports Criteria: Requested information should be readily available for audit examination. The Housing Authority is responsible for the proper administration and enforcement of the Federal labor standards provisions on contracts covered by Davis-Bacon requirements, and therefore must maintain all Davis-Bacon certified payroll reports (OMB No. 1235-0008) for the entire length of the contract. Condition: The Fayetteville Housing Authority was unable to locate all of the weekly Davis-Bacon certified payroll reports related to the Emergency Grant. Questioned Costs: Undetermined due to missing documentation. Effect: We are unable to determine that all laborers were paid the prevailing wage rate, as determined by the United States Department of Labor. Cause: Lack of Management oversight. Recommendation: We recommend the Fayetteville Housing Authority’s management place a greater emphasis in safe keeping its records and ensuring that all information requested is readily available for audit examination. We also recommend that the Fayetteville Housing Authority monitor labor standard compliance by conducting interviews with construction workers at the job site, reviews payroll reports, and oversees any additional enforcement actions that may be required.
2020-012 Missing Documentation - Receipts for Credit Card Purchases Criteria: Requested information should be readily available for audit examination. Condition: The Fayetteville Housing Authority was unable to locate some receipts to credit card purchases for audit examination. Questioned Costs: Undetermined due to missing documentation. Effect: We are unable to determine the accuracy of the financial statement amounts due to lack of supporting documentation. Cause: The Fayetteville Housing Authority did not secure all the required receipts for supporting documentation. Recommendation: We recommend the Fayetteville Housing Authority’s management place a greater emphasis in safe keeping its records to ensure all receipts for every transaction is accounted for.
2020-013 Internal Controls Were Not Followed Criteria: Invoices for accounts payables should be properly authorized for payment prior to entry into the computer software. Condition: Invoices for accounts payables were not properly authorized by Fayetteville Housing Authority management. Questioned Costs: Unknown. Effect: No clear document trail on disbursements. Cause: The Fayetteville Housing Authority did not place emphasis on ensuring that the invoices paid were being reviewed and authorized. Recommendation: We recommend that the Fayetteville Housing Authority ensure that all invoices are adequately initialed or signed to ensure that they are correct and authorized.
2020-014 Misappropriation of Federal Funds - Cell Phone Tower Criteria: Housing Authorities are permitted to use federal funds and funds derived from federal sources for approved activities only. Condition: The Fayetteville Housing Authority issued a forgivable loan to FHA Development, Inc. in the amount of $18,000.00 from monies received in rent from a cell phone tower that is located on top of the high-rise building, which is considered Federal property. We noted a Board Resolution (#1194) stating that the monies received from the rental of the top of the high-rise building to be considered non-federal money. Questioned Costs: $18,000.00 Effect: Because the cell phone tower sits atop the Hillcrest Tower building, which is part of the Fayetteville Housing Authority property, any income derived from this source is considered to be federal money. Cause: Lack of oversight by Fayetteville Housing Authority management. Recommendation: We recommend that the Fayetteville Housing Authority requires FHA Development, Inc. to immediately repay to the Fayetteville Housing Authority the $18,000.00 in federal money that was misappropriated.
2020-015 Misappropriation of Federal Funds - Improper Receivable Criteria: A Housing Authority is required to maintain a repayment plan with a component unit for any costs incurred by the Housing Authority on behalf of the component unit. Condition: The Fayetteville Housing Authority has an accounts receivable balance in the amount of $107,360.56 which represents costs incurred by the FHA Development, Inc. but paid by the Fayetteville Housing Authority. Questioned Costs: $107,360.56 Effect: Federal money received by the Fayetteville Housing Authority from the federal sources was misappropriated to subsidize the operations of the FHA Development, Inc.. Cause: Lack of oversight by Housing Authority management. Recommendation: We recommend that the Fayetteville Housing Authority requires the FHA Development, Inc. to immediately repay to the Fayetteville Housing Authority the $107,360.56 in federal money that was misappropriated.
2020-016 Misappropriation of Federal Funds - Improper Allocation of Housing Authority Funds and Staff Criteria: A Housing Authority is required to maintain a cost sharing agreement with a component unit for any costs incurred by the Housing Authority on behalf of the component unit. Condition: The Fayetteville Housing Authority has incurred direct costs on behalf of the FHA Development, Inc. Furthermore, it was observed at the time of our audit that Fayetteville Housing Authority maintenance staff were performing work on the FHA Development, Inc. properties. Questioned Costs: Unknown Effect: Federal money received by the Fayetteville Housing Authority from the federal sources was misappropriated to subsidize the operations of the FHA Development, Inc. Cause: Lack of oversight by Fayetteville Housing Authority management. Recommendation: We recommend that the Fayetteville Housing Authority discontinue incurring expenses on behalf of the FHA Development, Inc. and discontinue utilizing Fayetteville Housing Authority staff time on the FHA Development, Inc. properties until the proper cost sharing agreement is in place.
2020-017 Misstatements in Financial Statements Criteria: A Housing Authority is required to prepare accurate financial statements free from material misstatement. Condition: The financial statements for the Fayetteville Housing Authority contain the following misstatements: The financial activity for the FHA Development, Inc. was included in the Business Activities Project in the FDS submission and in detail accounts of the general ledger. The FHA Development, Inc. Company, Inc. is a 501(3)(c) Not for Profit Corporation and as such, should be presented on the financial statements as a discretely presented component unit. The current accounting and presentation obscure the activity of the FHA Development, Inc. by imbedding it within the financial statements of the Fayetteville Housing Authority, which is misleading. Questioned Costs: Unknown Effect: The financial statements of the Fayetteville Housing Authority are misstated. Cause: Fayetteville Housing Authority management did not properly prepare and submit their unaudited financial statement submission to HUD Recommendation: We recommend that the Fayetteville Housing Authority properly prepare their financial statements to present the FHA Development, Inc. as a discretely presented component unit.
2020-018 Unresponsive Attorney Criteria: An attorney for a Housing Authority is required to respond to auditor inquiries on behalf of the Housing Authority. Condition: During our audit we requested a description of any and all material pending or threatened litigation, claims and assessments (excluding unasserted claims and assessments). Questioned Costs: Unknown Effect: The Fayetteville Housing Authority may be subject to pending or actual litigation which should be disclosed in the notes to the financial statements. Cause: Fayetteville Housing Authority management did not ensure a response from their attorney. Recommendation: We recommend that the Fayetteville Housing Authority properly obtain the requested response from its attorney.