Audit 318813

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-005 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income Public and Indian Housing Program – CFDA 14.850 Material Weakness in Internal Control and Material Noncompliance Criteria: The Authority receives invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to Form 52722 to calculate the utility expense level (UEL). The UEL is a primary component of the operating subsidy grant revenue of the Authority, which is calculated on Form 52723. Form 52723 uses a formula to calculate the Operating Fund Revenue for the Authority. The calculation is generally based on prepopulated data calculated by HUD. However, in some cases, the formulaic fields are not prepopulated. Form 52722 and 52723 need to be reported correctly to ensure the operating subsidy grant revenue is calculated correctly for the future period. Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion. Cause: Former employees of the Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. Furthermore, HUD Form 52722 and 52723 are not accessible to the Authority through HUD’s website. Effect: The Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger as required by HUD. The Authority is not in compliance with this reporting requirement. Failure to properly maintain records could lead to significant issues in funding. Questioned Cost: None Recommendation: The Authority should retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to locate hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. We will retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit.

2022-005 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income Public and Indian Housing Program – CFDA 14.850 Material Weakness in Internal Control and Material Noncompliance Criteria: The Authority receives invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to Form 52722 to calculate the utility expense level (UEL). The UEL is a primary component of the operating subsidy grant revenue of the Authority, which is calculated on Form 52723. Form 52723 uses a formula to calculate the Operating Fund Revenue for the Authority. The calculation is generally based on prepopulated data calculated by HUD. However, in some cases, the formulaic fields are not prepopulated. Form 52722 and 52723 need to be reported correctly to ensure the operating subsidy grant revenue is calculated correctly for the future period. Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion. Cause: Former employees of the Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. Furthermore, HUD Form 52722 and 52723 are not accessible to the Authority through HUD’s website. Effect: The Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger as required by HUD. The Authority is not in compliance with this reporting requirement. Failure to properly maintain records could lead to significant issues in funding. Questioned Cost: None Recommendation: The Authority should retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to locate hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. We will retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Exceptions were noted as follows: • 3 tenant file errors where the HAP contract was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). • 1 tenant file error where the tenant’s application date, time, and preference did not agree to the date, time, and preference recorded on the waiting list. The tenant should have been housed earlier based on the tenant’s application date, time, and preference. • 1 tenant file had the following errors: o The HAP was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). o The tenant’s application date and time did not agree to the date, time, on the waiting list. The tenant should have been housed earlier based on their application date, time, and preference. • A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority’s administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority’s system through a lottery ranking technique. This is not in compliance with the Authority’s administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program. Questioned Costs: None. Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Exceptions were noted as follows: • 3 tenant file errors where the HAP contract was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). • 1 tenant file error where the tenant’s application date, time, and preference did not agree to the date, time, and preference recorded on the waiting list. The tenant should have been housed earlier based on the tenant’s application date, time, and preference. • 1 tenant file had the following errors: o The HAP was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). o The tenant’s application date and time did not agree to the date, time, on the waiting list. The tenant should have been housed earlier based on their application date, time, and preference. • A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority’s administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority’s system through a lottery ranking technique. This is not in compliance with the Authority’s administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program. Questioned Costs: None. Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Exceptions were noted as follows: • 3 tenant file errors where the HAP contract was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). • 1 tenant file error where the tenant’s application date, time, and preference did not agree to the date, time, and preference recorded on the waiting list. The tenant should have been housed earlier based on the tenant’s application date, time, and preference. • 1 tenant file had the following errors: o The HAP was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). o The tenant’s application date and time did not agree to the date, time, on the waiting list. The tenant should have been housed earlier based on their application date, time, and preference. • A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority’s administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority’s system through a lottery ranking technique. This is not in compliance with the Authority’s administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program. Questioned Costs: None. Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-005 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income Public and Indian Housing Program – CFDA 14.850 Material Weakness in Internal Control and Material Noncompliance Criteria: The Authority receives invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to Form 52722 to calculate the utility expense level (UEL). The UEL is a primary component of the operating subsidy grant revenue of the Authority, which is calculated on Form 52723. Form 52723 uses a formula to calculate the Operating Fund Revenue for the Authority. The calculation is generally based on prepopulated data calculated by HUD. However, in some cases, the formulaic fields are not prepopulated. Form 52722 and 52723 need to be reported correctly to ensure the operating subsidy grant revenue is calculated correctly for the future period. Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion. Cause: Former employees of the Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. Furthermore, HUD Form 52722 and 52723 are not accessible to the Authority through HUD’s website. Effect: The Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger as required by HUD. The Authority is not in compliance with this reporting requirement. Failure to properly maintain records could lead to significant issues in funding. Questioned Cost: None Recommendation: The Authority should retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to locate hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. We will retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit.

2022-005 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income Public and Indian Housing Program – CFDA 14.850 Material Weakness in Internal Control and Material Noncompliance Criteria: The Authority receives invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to Form 52722 to calculate the utility expense level (UEL). The UEL is a primary component of the operating subsidy grant revenue of the Authority, which is calculated on Form 52723. Form 52723 uses a formula to calculate the Operating Fund Revenue for the Authority. The calculation is generally based on prepopulated data calculated by HUD. However, in some cases, the formulaic fields are not prepopulated. Form 52722 and 52723 need to be reported correctly to ensure the operating subsidy grant revenue is calculated correctly for the future period. Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion. Cause: Former employees of the Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. Furthermore, HUD Form 52722 and 52723 are not accessible to the Authority through HUD’s website. Effect: The Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger as required by HUD. The Authority is not in compliance with this reporting requirement. Failure to properly maintain records could lead to significant issues in funding. Questioned Cost: None Recommendation: The Authority should retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to locate hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. We will retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Exceptions were noted as follows: • 3 tenant file errors where the HAP contract was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). • 1 tenant file error where the tenant’s application date, time, and preference did not agree to the date, time, and preference recorded on the waiting list. The tenant should have been housed earlier based on the tenant’s application date, time, and preference. • 1 tenant file had the following errors: o The HAP was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). o The tenant’s application date and time did not agree to the date, time, on the waiting list. The tenant should have been housed earlier based on their application date, time, and preference. • A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority’s administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority’s system through a lottery ranking technique. This is not in compliance with the Authority’s administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program. Questioned Costs: None. Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Exceptions were noted as follows: • 3 tenant file errors where the HAP contract was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). • 1 tenant file error where the tenant’s application date, time, and preference did not agree to the date, time, and preference recorded on the waiting list. The tenant should have been housed earlier based on the tenant’s application date, time, and preference. • 1 tenant file had the following errors: o The HAP was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). o The tenant’s application date and time did not agree to the date, time, on the waiting list. The tenant should have been housed earlier based on their application date, time, and preference. • A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority’s administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority’s system through a lottery ranking technique. This is not in compliance with the Authority’s administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program. Questioned Costs: None. Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Exceptions were noted as follows: • 3 tenant file errors where the HAP contract was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). • 1 tenant file error where the tenant’s application date, time, and preference did not agree to the date, time, and preference recorded on the waiting list. The tenant should have been housed earlier based on the tenant’s application date, time, and preference. • 1 tenant file had the following errors: o The HAP was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). o The tenant’s application date and time did not agree to the date, time, on the waiting list. The tenant should have been housed earlier based on their application date, time, and preference. • A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority’s administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority’s system through a lottery ranking technique. This is not in compliance with the Authority’s administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program. Questioned Costs: None. Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.