Audit 310743

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant’s eligibility and also determine the tenants’ portion of rent and the Authority’s portion of the rent. 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). (4) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances -- Finding 29 -- The Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances -- Finding 49 -- The income reported on the 50058 was not supported. 34 -- The assets reported on the 50058 was not supported. 35 -- The expenses reported on the 50058 was not supported. 45 -- The Authority did not review the tenant’s information on an annual basis 40 -- The file was missing the HUD-9886 authorization form. 41 -- The file was missing the Authority general release form. 48 -- The Audit Memo Trail in Yardi was not approved by the housing specialist. 49 -- The HAP information reported in the 50058 did not agree to support. 32 -- The HAP Contract could not be verified to supporting documents. 46 -- The Authority's internal control checklist was missing in the tenant file. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 housing choice voucher and mainstream voucher tenant files tested, 49 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as it’s administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, and 2022-001. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility determination and verification or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant’s eligibility and also determine the tenants’ portion of rent and the Authority’s portion of the rent. 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). (4) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances -- Finding 29 -- The Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances -- Finding 49 -- The income reported on the 50058 was not supported. 34 -- The assets reported on the 50058 was not supported. 35 -- The expenses reported on the 50058 was not supported. 45 -- The Authority did not review the tenant’s information on an annual basis 40 -- The file was missing the HUD-9886 authorization form. 41 -- The file was missing the Authority general release form. 48 -- The Audit Memo Trail in Yardi was not approved by the housing specialist. 49 -- The HAP information reported in the 50058 did not agree to support. 32 -- The HAP Contract could not be verified to supporting documents. 46 -- The Authority's internal control checklist was missing in the tenant file. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 housing choice voucher and mainstream voucher tenant files tested, 49 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as it’s administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, and 2022-001. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility determination and verification or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant’s eligibility and also determine the tenants’ portion of rent and the Authority’s portion of the rent. 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). (4) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances -- Finding 29 -- The Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances -- Finding 49 -- The income reported on the 50058 was not supported. 34 -- The assets reported on the 50058 was not supported. 35 -- The expenses reported on the 50058 was not supported. 45 -- The Authority did not review the tenant’s information on an annual basis 40 -- The file was missing the HUD-9886 authorization form. 41 -- The file was missing the Authority general release form. 48 -- The Audit Memo Trail in Yardi was not approved by the housing specialist. 49 -- The HAP information reported in the 50058 did not agree to support. 32 -- The HAP Contract could not be verified to supporting documents. 46 -- The Authority's internal control checklist was missing in the tenant file. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 housing choice voucher and mainstream voucher tenant files tested, 49 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as it’s administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, and 2022-001. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility determination and verification or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. 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). In addition, all HCV units are required to be inspected annually. The PHA must inspect the unit leased to a family at least annually 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)). Condition: During the testing of 120 Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Failed HQS Inspections Number of Instances -- Finding 7 -- The Authority did not properly abate HAP after the second failed inspection and/or the tenants passed inspection reports and dates were missing and it could not be verified if the HAP payments were properly abated for the units. Annual HQS Inspections Number of Instances -- Finding 19 -- The annual inspection was not performed in a timely manner, the Authority failed to enforce regulation, or the inspection was unable to be located. 2 -- The Authority's HQS inspection was missing Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 files tested for failed inspections, 7 files contained errors as noted above. Out of 60 files tested for annual inspections, 19 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely or to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, and 2022-002. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS inspections. We recommend the Authority to hire outside consultants to assist with inspections or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. 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). In addition, all HCV units are required to be inspected annually. The PHA must inspect the unit leased to a family at least annually 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)). Condition: During the testing of 120 Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Failed HQS Inspections Number of Instances -- Finding 7 -- The Authority did not properly abate HAP after the second failed inspection and/or the tenants passed inspection reports and dates were missing and it could not be verified if the HAP payments were properly abated for the units. Annual HQS Inspections Number of Instances -- Finding 19 -- The annual inspection was not performed in a timely manner, the Authority failed to enforce regulation, or the inspection was unable to be located. 2 -- The Authority's HQS inspection was missing Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 files tested for failed inspections, 7 files contained errors as noted above. Out of 60 files tested for annual inspections, 19 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely or to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, and 2022-002. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS inspections. We recommend the Authority to hire outside consultants to assist with inspections or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. 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). In addition, all HCV units are required to be inspected annually. The PHA must inspect the unit leased to a family at least annually 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)). Condition: During the testing of 120 Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Failed HQS Inspections Number of Instances -- Finding 7 -- The Authority did not properly abate HAP after the second failed inspection and/or the tenants passed inspection reports and dates were missing and it could not be verified if the HAP payments were properly abated for the units. Annual HQS Inspections Number of Instances -- Finding 19 -- The annual inspection was not performed in a timely manner, the Authority failed to enforce regulation, or the inspection was unable to be located. 2 -- The Authority's HQS inspection was missing Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 files tested for failed inspections, 7 files contained errors as noted above. Out of 60 files tested for annual inspections, 19 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely or to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, and 2022-002. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS inspections. We recommend the Authority to hire outside consultants to assist with inspections or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must determine that the rent to 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 five percent 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 (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of the Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances -- Finding 17 -- The rent reasonableness was not performed prior to the effective date. 5 -- The tenant file did not document completion of rent determination showing 3 comparable for units located in the same area, with similar amenities, size and condition. 5 -- The approved rent determination form was not completed to ensure that it was properly entered into the Yardi system by agreeing it to the rent amount on the HUD 50058. 13 -- The PBV agreement establishing the contract rent for 1 bedroom size units could not be provided. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: During our testing, we reviewed 120 tenant files that required rent reasonableness determinations; 35 tenant files contained errors as noted above with multiple tenant files containing more than one error. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount or failed to properly maintain the applicable forms to support the rent reasonableness performed. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, and 2022-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must determine that the rent to 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 five percent 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 (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of the Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances -- Finding 17 -- The rent reasonableness was not performed prior to the effective date. 5 -- The tenant file did not document completion of rent determination showing 3 comparable for units located in the same area, with similar amenities, size and condition. 5 -- The approved rent determination form was not completed to ensure that it was properly entered into the Yardi system by agreeing it to the rent amount on the HUD 50058. 13 -- The PBV agreement establishing the contract rent for 1 bedroom size units could not be provided. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: During our testing, we reviewed 120 tenant files that required rent reasonableness determinations; 35 tenant files contained errors as noted above with multiple tenant files containing more than one error. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount or failed to properly maintain the applicable forms to support the rent reasonableness performed. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, and 2022-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must determine that the rent to 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 five percent 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 (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of the Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances -- Finding 17 -- The rent reasonableness was not performed prior to the effective date. 5 -- The tenant file did not document completion of rent determination showing 3 comparable for units located in the same area, with similar amenities, size and condition. 5 -- The approved rent determination form was not completed to ensure that it was properly entered into the Yardi system by agreeing it to the rent amount on the HUD 50058. 13 -- The PBV agreement establishing the contract rent for 1 bedroom size units could not be provided. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: During our testing, we reviewed 120 tenant files that required rent reasonableness determinations; 35 tenant files contained errors as noted above with multiple tenant files containing more than one error. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount or failed to properly maintain the applicable forms to support the rent reasonableness performed. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, and 2022-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances -- Finding 25 -- The HUD-52578b Statement of Family Responsibility was signed and completed after the effective date. 14 -- The HUD-52578b Statement of Family Responsibility are missing. 2 -- The referral forms were missing from the tenant files. 2 -- The HUD-52646 vouchers were not properly signed. 14 -- The acceptance letters were missing from the tenant files. 6 -- The original applications were missing from the tenant files. 6 -- The original applications were missing from the tenant files. Tenant Selected from the Waiting List Number of Instances -- Finding 35 -- The tenant was not admitted in accordance with the applicant's selection policies found in the administrative plan. 2 -- The Authority provided status on the open items report but failed to provide supporting documentation or actions taken. 3 -- There was no documentation of reason for the tenant being denied from the program. 1 -- There was no letter notifying the tenant that their name had been selected from the waiting list. Questioned Costs: Undeterminable Context: Out of 60 new tenant files tested, 40 contained the errors noted above. Out of 60 tenants selected from the waiting list files tested, 43 files contained the errors noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, and 2022-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are notified appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances -- Finding 25 -- The HUD-52578b Statement of Family Responsibility was signed and completed after the effective date. 14 -- The HUD-52578b Statement of Family Responsibility are missing. 2 -- The referral forms were missing from the tenant files. 2 -- The HUD-52646 vouchers were not properly signed. 14 -- The acceptance letters were missing from the tenant files. 6 -- The original applications were missing from the tenant files. 6 -- The original applications were missing from the tenant files. Tenant Selected from the Waiting List Number of Instances -- Finding 35 -- The tenant was not admitted in accordance with the applicant's selection policies found in the administrative plan. 2 -- The Authority provided status on the open items report but failed to provide supporting documentation or actions taken. 3 -- There was no documentation of reason for the tenant being denied from the program. 1 -- There was no letter notifying the tenant that their name had been selected from the waiting list. Questioned Costs: Undeterminable Context: Out of 60 new tenant files tested, 40 contained the errors noted above. Out of 60 tenants selected from the waiting list files tested, 43 files contained the errors noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, and 2022-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are notified appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances -- Finding 25 -- The HUD-52578b Statement of Family Responsibility was signed and completed after the effective date. 14 -- The HUD-52578b Statement of Family Responsibility are missing. 2 -- The referral forms were missing from the tenant files. 2 -- The HUD-52646 vouchers were not properly signed. 14 -- The acceptance letters were missing from the tenant files. 6 -- The original applications were missing from the tenant files. 6 -- The original applications were missing from the tenant files. Tenant Selected from the Waiting List Number of Instances -- Finding 35 -- The tenant was not admitted in accordance with the applicant's selection policies found in the administrative plan. 2 -- The Authority provided status on the open items report but failed to provide supporting documentation or actions taken. 3 -- There was no documentation of reason for the tenant being denied from the program. 1 -- There was no letter notifying the tenant that their name had been selected from the waiting list. Questioned Costs: Undeterminable Context: Out of 60 new tenant files tested, 40 contained the errors noted above. Out of 60 tenants selected from the waiting list files tested, 43 files contained the errors noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, and 2022-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are notified appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form 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. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances -- Finding 5 -- The HUD-50058 form was not uploaded to PIC at all 4 -- The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 9 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special report requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005. Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form 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. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances -- Finding 5 -- The HUD-50058 form was not uploaded to PIC at all 4 -- The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 9 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special report requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005. Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form 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. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances -- Finding 5 -- The HUD-50058 form was not uploaded to PIC at all 4 -- The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 9 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special report requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005. Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) 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 household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). 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 960.259). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). (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 sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259). (4) Select tenants from the public housing waiting list (see III.N.2, “Special Tests and Provisions – Public Housing Waiting List”) (24 CFR sections 960.206 and 960.208). (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 sections 960.253, 960.257, and 960.259). Condition: During the testing of the Public Housing Program tenant files, a compliance deficiency was noted: Of the 60 tenant files provided, auditor noted the following items: Number of Instances -- Finding 5 -- The tenant file was missing a signed 9886 general release form for one or more of the residents. 4 -- The tenant file was missing a signed 214 form for one or more tenants. 9 -- The quality control checklist was not signed by the housing specialist. 1 -- The recertification was not completed for the selected effective date. 6 -- The income reported on the HUD-50058 was incorrectly reported or support could not be provided for the reported income. 3 -- The family income and composition was not reexamined annually. 1 -- The expenses reported on the HUD-50058 was incorrectly reported. 2 -- The assets reported on the HUD-50058 was incorrectly reported. Undeterminable; estimated to be over $25,000 Context: Out of 60 public housing tenant files tested, 22 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their ACOP. Effect: The Authority is not in compliance with federal regulations regarding the verification of the tenants income and maintaining adequate documents per the compliance requirements. Repeat Finding: No. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must establish and adopt written policies for admission of tenants. The PHA tenant selection policies must include requirements for applications and waiting lists, description of the policies for selection of applicants from the waiting lists, and policies for verification and documentation of information relevant to acceptance or rejections of an applicant (24 CFR sections 960.202 through 960.206). Condition: During the testing of the Low Rent Public Housing Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants The Housing Authority failed to follow and enforce it's ACOP in adding families to the waiting list. Rent Cafe was used for adding families to the waiting list. However, the Housing Authority could not verify the workflow in adding families to the waiting list upon receiving an application in Rent Cafe. Also, during the fiscal year, they noticed applicants were left on Rent Cafe, without pushing the application to Yardi. This resulted in those families not being properly selected from the waitlist. Tenant Selected from the Waiting List Number of Instances -- Finding 8 -- The housing authority failed to provide documentation showing date/time of the original application through Rent Cafe or any other alternate system. 7 -- The housing authority did not follow controls for selection of the families from the waiting list. Questioned Costs: Undeterminable Context: We were unable to test a sample of waiting list-new tenants due to the Authority not properly tracking new tenants. Out of 8 tenants files tested for selection from the waiting list, 8 files contained errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority is not in compliance with federal regulations regarding the verification of the tenants income and maintaining adequate documents per the compliance requirements. Repeat Finding: No. Recommendation: We recommend management review policies and procedures in place and develop work processes to ensure it is in compliance with the ACOP and HUD. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant’s eligibility and also determine the tenants’ portion of rent and the Authority’s portion of the rent. 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). (4) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances -- Finding 29 -- The Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances -- Finding 49 -- The income reported on the 50058 was not supported. 34 -- The assets reported on the 50058 was not supported. 35 -- The expenses reported on the 50058 was not supported. 45 -- The Authority did not review the tenant’s information on an annual basis 40 -- The file was missing the HUD-9886 authorization form. 41 -- The file was missing the Authority general release form. 48 -- The Audit Memo Trail in Yardi was not approved by the housing specialist. 49 -- The HAP information reported in the 50058 did not agree to support. 32 -- The HAP Contract could not be verified to supporting documents. 46 -- The Authority's internal control checklist was missing in the tenant file. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 housing choice voucher and mainstream voucher tenant files tested, 49 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as it’s administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, and 2022-001. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility determination and verification or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant’s eligibility and also determine the tenants’ portion of rent and the Authority’s portion of the rent. 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). (4) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances -- Finding 29 -- The Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances -- Finding 49 -- The income reported on the 50058 was not supported. 34 -- The assets reported on the 50058 was not supported. 35 -- The expenses reported on the 50058 was not supported. 45 -- The Authority did not review the tenant’s information on an annual basis 40 -- The file was missing the HUD-9886 authorization form. 41 -- The file was missing the Authority general release form. 48 -- The Audit Memo Trail in Yardi was not approved by the housing specialist. 49 -- The HAP information reported in the 50058 did not agree to support. 32 -- The HAP Contract could not be verified to supporting documents. 46 -- The Authority's internal control checklist was missing in the tenant file. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 housing choice voucher and mainstream voucher tenant files tested, 49 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as it’s administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, and 2022-001. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility determination and verification or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant’s eligibility and also determine the tenants’ portion of rent and the Authority’s portion of the rent. 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). (4) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances -- Finding 29 -- The Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances -- Finding 49 -- The income reported on the 50058 was not supported. 34 -- The assets reported on the 50058 was not supported. 35 -- The expenses reported on the 50058 was not supported. 45 -- The Authority did not review the tenant’s information on an annual basis 40 -- The file was missing the HUD-9886 authorization form. 41 -- The file was missing the Authority general release form. 48 -- The Audit Memo Trail in Yardi was not approved by the housing specialist. 49 -- The HAP information reported in the 50058 did not agree to support. 32 -- The HAP Contract could not be verified to supporting documents. 46 -- The Authority's internal control checklist was missing in the tenant file. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 housing choice voucher and mainstream voucher tenant files tested, 49 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as it’s administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, and 2022-001. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility determination and verification or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. 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). In addition, all HCV units are required to be inspected annually. The PHA must inspect the unit leased to a family at least annually 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)). Condition: During the testing of 120 Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Failed HQS Inspections Number of Instances -- Finding 7 -- The Authority did not properly abate HAP after the second failed inspection and/or the tenants passed inspection reports and dates were missing and it could not be verified if the HAP payments were properly abated for the units. Annual HQS Inspections Number of Instances -- Finding 19 -- The annual inspection was not performed in a timely manner, the Authority failed to enforce regulation, or the inspection was unable to be located. 2 -- The Authority's HQS inspection was missing Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 files tested for failed inspections, 7 files contained errors as noted above. Out of 60 files tested for annual inspections, 19 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely or to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, and 2022-002. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS inspections. We recommend the Authority to hire outside consultants to assist with inspections or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. 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). In addition, all HCV units are required to be inspected annually. The PHA must inspect the unit leased to a family at least annually 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)). Condition: During the testing of 120 Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Failed HQS Inspections Number of Instances -- Finding 7 -- The Authority did not properly abate HAP after the second failed inspection and/or the tenants passed inspection reports and dates were missing and it could not be verified if the HAP payments were properly abated for the units. Annual HQS Inspections Number of Instances -- Finding 19 -- The annual inspection was not performed in a timely manner, the Authority failed to enforce regulation, or the inspection was unable to be located. 2 -- The Authority's HQS inspection was missing Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 files tested for failed inspections, 7 files contained errors as noted above. Out of 60 files tested for annual inspections, 19 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely or to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, and 2022-002. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS inspections. We recommend the Authority to hire outside consultants to assist with inspections or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. 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). In addition, all HCV units are required to be inspected annually. The PHA must inspect the unit leased to a family at least annually 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)). Condition: During the testing of 120 Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Failed HQS Inspections Number of Instances -- Finding 7 -- The Authority did not properly abate HAP after the second failed inspection and/or the tenants passed inspection reports and dates were missing and it could not be verified if the HAP payments were properly abated for the units. Annual HQS Inspections Number of Instances -- Finding 19 -- The annual inspection was not performed in a timely manner, the Authority failed to enforce regulation, or the inspection was unable to be located. 2 -- The Authority's HQS inspection was missing Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 files tested for failed inspections, 7 files contained errors as noted above. Out of 60 files tested for annual inspections, 19 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely or to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, and 2022-002. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS inspections. We recommend the Authority to hire outside consultants to assist with inspections or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must determine that the rent to 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 five percent 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 (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of the Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances -- Finding 17 -- The rent reasonableness was not performed prior to the effective date. 5 -- The tenant file did not document completion of rent determination showing 3 comparable for units located in the same area, with similar amenities, size and condition. 5 -- The approved rent determination form was not completed to ensure that it was properly entered into the Yardi system by agreeing it to the rent amount on the HUD 50058. 13 -- The PBV agreement establishing the contract rent for 1 bedroom size units could not be provided. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: During our testing, we reviewed 120 tenant files that required rent reasonableness determinations; 35 tenant files contained errors as noted above with multiple tenant files containing more than one error. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount or failed to properly maintain the applicable forms to support the rent reasonableness performed. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, and 2022-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must determine that the rent to 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 five percent 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 (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of the Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances -- Finding 17 -- The rent reasonableness was not performed prior to the effective date. 5 -- The tenant file did not document completion of rent determination showing 3 comparable for units located in the same area, with similar amenities, size and condition. 5 -- The approved rent determination form was not completed to ensure that it was properly entered into the Yardi system by agreeing it to the rent amount on the HUD 50058. 13 -- The PBV agreement establishing the contract rent for 1 bedroom size units could not be provided. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: During our testing, we reviewed 120 tenant files that required rent reasonableness determinations; 35 tenant files contained errors as noted above with multiple tenant files containing more than one error. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount or failed to properly maintain the applicable forms to support the rent reasonableness performed. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, and 2022-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must determine that the rent to 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 five percent 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 (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of the Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances -- Finding 17 -- The rent reasonableness was not performed prior to the effective date. 5 -- The tenant file did not document completion of rent determination showing 3 comparable for units located in the same area, with similar amenities, size and condition. 5 -- The approved rent determination form was not completed to ensure that it was properly entered into the Yardi system by agreeing it to the rent amount on the HUD 50058. 13 -- The PBV agreement establishing the contract rent for 1 bedroom size units could not be provided. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: During our testing, we reviewed 120 tenant files that required rent reasonableness determinations; 35 tenant files contained errors as noted above with multiple tenant files containing more than one error. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount or failed to properly maintain the applicable forms to support the rent reasonableness performed. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, and 2022-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances -- Finding 25 -- The HUD-52578b Statement of Family Responsibility was signed and completed after the effective date. 14 -- The HUD-52578b Statement of Family Responsibility are missing. 2 -- The referral forms were missing from the tenant files. 2 -- The HUD-52646 vouchers were not properly signed. 14 -- The acceptance letters were missing from the tenant files. 6 -- The original applications were missing from the tenant files. 6 -- The original applications were missing from the tenant files. Tenant Selected from the Waiting List Number of Instances -- Finding 35 -- The tenant was not admitted in accordance with the applicant's selection policies found in the administrative plan. 2 -- The Authority provided status on the open items report but failed to provide supporting documentation or actions taken. 3 -- There was no documentation of reason for the tenant being denied from the program. 1 -- There was no letter notifying the tenant that their name had been selected from the waiting list. Questioned Costs: Undeterminable Context: Out of 60 new tenant files tested, 40 contained the errors noted above. Out of 60 tenants selected from the waiting list files tested, 43 files contained the errors noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, and 2022-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are notified appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances -- Finding 25 -- The HUD-52578b Statement of Family Responsibility was signed and completed after the effective date. 14 -- The HUD-52578b Statement of Family Responsibility are missing. 2 -- The referral forms were missing from the tenant files. 2 -- The HUD-52646 vouchers were not properly signed. 14 -- The acceptance letters were missing from the tenant files. 6 -- The original applications were missing from the tenant files. 6 -- The original applications were missing from the tenant files. Tenant Selected from the Waiting List Number of Instances -- Finding 35 -- The tenant was not admitted in accordance with the applicant's selection policies found in the administrative plan. 2 -- The Authority provided status on the open items report but failed to provide supporting documentation or actions taken. 3 -- There was no documentation of reason for the tenant being denied from the program. 1 -- There was no letter notifying the tenant that their name had been selected from the waiting list. Questioned Costs: Undeterminable Context: Out of 60 new tenant files tested, 40 contained the errors noted above. Out of 60 tenants selected from the waiting list files tested, 43 files contained the errors noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, and 2022-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are notified appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances -- Finding 25 -- The HUD-52578b Statement of Family Responsibility was signed and completed after the effective date. 14 -- The HUD-52578b Statement of Family Responsibility are missing. 2 -- The referral forms were missing from the tenant files. 2 -- The HUD-52646 vouchers were not properly signed. 14 -- The acceptance letters were missing from the tenant files. 6 -- The original applications were missing from the tenant files. 6 -- The original applications were missing from the tenant files. Tenant Selected from the Waiting List Number of Instances -- Finding 35 -- The tenant was not admitted in accordance with the applicant's selection policies found in the administrative plan. 2 -- The Authority provided status on the open items report but failed to provide supporting documentation or actions taken. 3 -- There was no documentation of reason for the tenant being denied from the program. 1 -- There was no letter notifying the tenant that their name had been selected from the waiting list. Questioned Costs: Undeterminable Context: Out of 60 new tenant files tested, 40 contained the errors noted above. Out of 60 tenants selected from the waiting list files tested, 43 files contained the errors noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, and 2022-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are notified appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form 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. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances -- Finding 5 -- The HUD-50058 form was not uploaded to PIC at all 4 -- The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 9 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special report requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005. Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form 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. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances -- Finding 5 -- The HUD-50058 form was not uploaded to PIC at all 4 -- The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 9 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special report requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005. Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form 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. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances -- Finding 5 -- The HUD-50058 form was not uploaded to PIC at all 4 -- The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 9 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special report requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005. Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) 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 household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). 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 960.259). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). (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 sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259). (4) Select tenants from the public housing waiting list (see III.N.2, “Special Tests and Provisions – Public Housing Waiting List”) (24 CFR sections 960.206 and 960.208). (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 sections 960.253, 960.257, and 960.259). Condition: During the testing of the Public Housing Program tenant files, a compliance deficiency was noted: Of the 60 tenant files provided, auditor noted the following items: Number of Instances -- Finding 5 -- The tenant file was missing a signed 9886 general release form for one or more of the residents. 4 -- The tenant file was missing a signed 214 form for one or more tenants. 9 -- The quality control checklist was not signed by the housing specialist. 1 -- The recertification was not completed for the selected effective date. 6 -- The income reported on the HUD-50058 was incorrectly reported or support could not be provided for the reported income. 3 -- The family income and composition was not reexamined annually. 1 -- The expenses reported on the HUD-50058 was incorrectly reported. 2 -- The assets reported on the HUD-50058 was incorrectly reported. Undeterminable; estimated to be over $25,000 Context: Out of 60 public housing tenant files tested, 22 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their ACOP. Effect: The Authority is not in compliance with federal regulations regarding the verification of the tenants income and maintaining adequate documents per the compliance requirements. Repeat Finding: No. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must establish and adopt written policies for admission of tenants. The PHA tenant selection policies must include requirements for applications and waiting lists, description of the policies for selection of applicants from the waiting lists, and policies for verification and documentation of information relevant to acceptance or rejections of an applicant (24 CFR sections 960.202 through 960.206). Condition: During the testing of the Low Rent Public Housing Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants The Housing Authority failed to follow and enforce it's ACOP in adding families to the waiting list. Rent Cafe was used for adding families to the waiting list. However, the Housing Authority could not verify the workflow in adding families to the waiting list upon receiving an application in Rent Cafe. Also, during the fiscal year, they noticed applicants were left on Rent Cafe, without pushing the application to Yardi. This resulted in those families not being properly selected from the waitlist. Tenant Selected from the Waiting List Number of Instances -- Finding 8 -- The housing authority failed to provide documentation showing date/time of the original application through Rent Cafe or any other alternate system. 7 -- The housing authority did not follow controls for selection of the families from the waiting list. Questioned Costs: Undeterminable Context: We were unable to test a sample of waiting list-new tenants due to the Authority not properly tracking new tenants. Out of 8 tenants files tested for selection from the waiting list, 8 files contained errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority is not in compliance with federal regulations regarding the verification of the tenants income and maintaining adequate documents per the compliance requirements. Repeat Finding: No. Recommendation: We recommend management review policies and procedures in place and develop work processes to ensure it is in compliance with the ACOP and HUD. Views of Responsible Officials: There is no disagreement with the audit finding.