Audit 319962

FY End
2023-12-31
Total Expended
$4.59M
Findings
6
Programs
3
Organization: Leominster Housing Authority (MA)
Year: 2023 Accepted: 2024-09-18
Auditor: Marcum LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
497307 2023-001 Significant Deficiency - L
497308 2023-002 Significant Deficiency - N
497309 2023-003 Significant Deficiency - E
1073749 2023-001 Significant Deficiency - L
1073750 2023-002 Significant Deficiency - N
1073751 2023-003 Significant Deficiency - E

Programs

ALN Program Spent Major Findings
14.871 Section 8 Housing Choice Vouchers $4.08M Yes 3
21.027 Coronavirus State and Local Fiscal Recovery Funds $435,230 Yes 0
14.896 Family Self-Sufficiency Program $69,501 - 0

Contacts

Name Title Type
DNYLKJ363MN6 Benjamin Gold Auditee
9785375300 Michael Guyder Auditor
No contacts on file

Notes to SEFA

Accounting Policies: NOTE 1 – BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Leominster Housing Authority, under programs of the federal government for the year ended December 31, 2023. The information in the schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirement, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of Leominster Housing Authority, it is not intended to and does not present the financial position, changes in net position or cash flows of Leominster Housing Authority. NOTE 2 – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Expenditures reported on the schedule are reported on the accrual basis of accounting. For cost-reimbursement awards, such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. For performance-based awards, expenditures reported represent amounts earned. De Minimis Rate Used: N Rate Explanation: The Leominster Housing Authority has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance.

Finding Details

2023-001 – REPORTING – PERFORMANCE REPORTING Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Section 8 Housing Choice Voucher Program CRITERIA PHA's quality control sample means an annual sample of files or records drawn in an unbiased manner and reviewed by an PHA supervisor (or by another qualified person other than the person who performed the original work) to determine if the work documented in the files or records conforms to program requirements. The minimum size of the PHA's quality control sample is as follows: Minimum number of files or records to be sampled 50 or less 5. 51-600 5 Plus 1 for each 50 (or part of 50) over 50. 601-2000 16 Plus 1 for each 100 (or part of 100) over 600. Over 2000 30 Plus 1 for each 200 (or part of 200) over 2000 Where the universe is: the number of admissions in the last year for each of the two quality control samples under the SEMAP indicator at § 985.3(a) Selection from the Waiting List; (25 CFR 985.2) CONDITION The Authority did not properly document the universe and sample selected for Indicator 1 – Selection from the Waiting List. CAUSE During the year, there was a transition in staff and as a result, the Authority was not able to provide documentation of the samples tested for indicator one or that they were pulled in an unbiased manner and reviewed by an individual other than the person who did the work. EFFECT The Authority may have potentially incorrectly reported the performance rating. QUESTIONED COSTS None Identified. CONTEXT The Authority conducts the SEMAP assessment on an annual basis. During the SEMAP sample selection process, the Authority needs to generate reports to accurately represent the universes related to each indicator. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority determine the quality control samples based on the universes defined by HUD. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2023-002- SPECIAL TESTS AND PROVISIONS – HQS ENFORCEMENT Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Section 8 Housing Choice Voucher Program CRITERIA The PHA must not make any housing assistance payments for a dwelling unit that fails to meet the HQS, unless the owner corrects the defect within the period specified by the PHA and the PHA verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). (24 CFR 982.404 (3)) CONDITION Re-inspections of units that failed HQS were not conducted timely for 2 out of 7 failed inspections selected. CAUSE Procedures were not in place to properly document the corrections of deficiencies in a timely manner and to abate the housing assistance payments when necessary. EFFECT The Authority may have paid housing assistance payments to landlords for units that failed to meet housing quality standards. QUESTIONED COSTS Estimated questioned costs are less than $25,000. CONTEXT There were 4,356 unit months leased for the Housing Choice Voucher Program. During 2023, there were a total of 65 failed inspections. Our sample was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that procedures be strengthened to ensure that documentation is maintained for all inspections and enforcements. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2023-003- ELIGIBILITY – ELIGIBILITY FOR INDIVIDUALS Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Section 8 Housing Choice Voucher Program CRITERIA (1) The PHA must conduct a reexamination of family income and composition at least annually. (2) Except as provided in paragraph (a)(3) of this section, the PHA must obtain and document in the tenant file third-party verification of the following factors, or must document in the tenant file why third-party verification was not available: (i) Reported family annual income; (ii) The value of assets; (iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income. CONDITION From our sample of 25 participants in the Housing Choice Voucher Program, we identified 5 instances of missing verifications or the verifications obtained did not agree to the amounts reported on the form 50058. CAUSE The Authority's system of third-party verifications of tenant’s income and choice of rent was not sufficient. EFFECT The Authority did not implement procedures that ensured proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. QUESTIONED COSTS None Identified. CONTEXT The Authority administers 404 vouchers in the Housing Choice Voucher Program. We selected a sample of 25 participants. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend policies and procedures are strengthened to ensure all proper documentation and annual recertification are maintained in all tenant files to document eligibility. In addition, the PHA should provide training to program staff. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2023-001 – REPORTING – PERFORMANCE REPORTING Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Section 8 Housing Choice Voucher Program CRITERIA PHA's quality control sample means an annual sample of files or records drawn in an unbiased manner and reviewed by an PHA supervisor (or by another qualified person other than the person who performed the original work) to determine if the work documented in the files or records conforms to program requirements. The minimum size of the PHA's quality control sample is as follows: Minimum number of files or records to be sampled 50 or less 5. 51-600 5 Plus 1 for each 50 (or part of 50) over 50. 601-2000 16 Plus 1 for each 100 (or part of 100) over 600. Over 2000 30 Plus 1 for each 200 (or part of 200) over 2000 Where the universe is: the number of admissions in the last year for each of the two quality control samples under the SEMAP indicator at § 985.3(a) Selection from the Waiting List; (25 CFR 985.2) CONDITION The Authority did not properly document the universe and sample selected for Indicator 1 – Selection from the Waiting List. CAUSE During the year, there was a transition in staff and as a result, the Authority was not able to provide documentation of the samples tested for indicator one or that they were pulled in an unbiased manner and reviewed by an individual other than the person who did the work. EFFECT The Authority may have potentially incorrectly reported the performance rating. QUESTIONED COSTS None Identified. CONTEXT The Authority conducts the SEMAP assessment on an annual basis. During the SEMAP sample selection process, the Authority needs to generate reports to accurately represent the universes related to each indicator. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority determine the quality control samples based on the universes defined by HUD. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2023-002- SPECIAL TESTS AND PROVISIONS – HQS ENFORCEMENT Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Section 8 Housing Choice Voucher Program CRITERIA The PHA must not make any housing assistance payments for a dwelling unit that fails to meet the HQS, unless the owner corrects the defect within the period specified by the PHA and the PHA verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). (24 CFR 982.404 (3)) CONDITION Re-inspections of units that failed HQS were not conducted timely for 2 out of 7 failed inspections selected. CAUSE Procedures were not in place to properly document the corrections of deficiencies in a timely manner and to abate the housing assistance payments when necessary. EFFECT The Authority may have paid housing assistance payments to landlords for units that failed to meet housing quality standards. QUESTIONED COSTS Estimated questioned costs are less than $25,000. CONTEXT There were 4,356 unit months leased for the Housing Choice Voucher Program. During 2023, there were a total of 65 failed inspections. Our sample was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that procedures be strengthened to ensure that documentation is maintained for all inspections and enforcements. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2023-003- ELIGIBILITY – ELIGIBILITY FOR INDIVIDUALS Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Section 8 Housing Choice Voucher Program CRITERIA (1) The PHA must conduct a reexamination of family income and composition at least annually. (2) Except as provided in paragraph (a)(3) of this section, the PHA must obtain and document in the tenant file third-party verification of the following factors, or must document in the tenant file why third-party verification was not available: (i) Reported family annual income; (ii) The value of assets; (iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income. CONDITION From our sample of 25 participants in the Housing Choice Voucher Program, we identified 5 instances of missing verifications or the verifications obtained did not agree to the amounts reported on the form 50058. CAUSE The Authority's system of third-party verifications of tenant’s income and choice of rent was not sufficient. EFFECT The Authority did not implement procedures that ensured proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. QUESTIONED COSTS None Identified. CONTEXT The Authority administers 404 vouchers in the Housing Choice Voucher Program. We selected a sample of 25 participants. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend policies and procedures are strengthened to ensure all proper documentation and annual recertification are maintained in all tenant files to document eligibility. In addition, the PHA should provide training to program staff. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.