Audit 322309

2023 – 002: Segregation of Duties - Compliance Federal agency: All Programs Federal program title: All Programs Assistance Listing No.: All Programs Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance Criteria or specific requirement: It is the Authority’s responsibility to establish and maintain systems of internal control over compliance that includes proper segregation of duties. Condition: The Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance to an appropriately low level. Context: While performing audit procedures, it was noted that the Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance with respect to compliance requirements related to eligibility and special tests and provisions. Cause: The Authority has not taken the appropriate steps to construct internal controls within their policies and procedures related to compliance with the Federal programs to the extent that the risk of noncompliance is reduced to an appropriately low level. Effect: As a result of the lack of segregation of duties and internal control, there were several compliance findings noted that resulted in material noncompliance with respect to eligibility and special tests and provisions. Repeat Finding: Yes; 2022-002. Recommendation: We recommend that the Authority’s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003: Income and Asset Verification Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: Income reported on the tenant assistance application was verified by the housing specialist by obtaining 3rd party verification of annual income. (3rd party verification includes direct confirmation from an employer, at least 4 paystubs, EIV report (required for 10/09 and later), SS award letter, printouts from Dept of Social Services for TANF, child support, etc.) (24 CFR 985.516). Assets reported on the tenant assistance application were verified by the leasing specialist by obtaining 3rd party verification of assets. If the tenant listed bank accounts, the PHA must obtain account balances from the bank or copies of bank statements. If the tenant receives SS income or wages, look at these forms to see if there is any indication of direct deposit. If so, the PHA should have gotten bank statements). (24 CFR 985.516). HAP/TAP was properly calculated using all verified information from above and was inputted into the HUD 50058 calculation. If the income reported is not correct per #2 above or there was no 3rd party verification of assets, this is incorrect as well. Condition: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: Known - Unknown | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not maintain evidence of completion of income verification as a part of the annual re-examination and six (6) tenant files did not contain third party verification of assets. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 985.516. Repeat Finding: Yes; 2022-003 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004: Reasonable Rent Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHS must maintain records to document the bases for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, five (5) tenant files did not include documentation of performance of rent reasonableness prior to the lease date. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005: Utility Allowance Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised. Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not include proper documentation of utility allowance. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006: Annual Inspections Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Authority failed to comply with the requirements of the annual HQS inspection as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-005 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 007: Housing Quality Standards (HQS) Enforcement Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (HQS), the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: During our testing, we noted the Authority failed to comply with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of twenty one (21) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-006 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 008: Financial Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA is required to submit an unaudited Financial Information within 2 months and audited annual Financial Report within 9 months to HUD electronically via the FASS-PH system. Condition: During our testing, we noted the Authority failed to comply with the requirements of the financial reporting as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: Unaudited REAC was submitted after the required two-month deadline. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002: Segregation of Duties - Compliance Federal agency: All Programs Federal program title: All Programs Assistance Listing No.: All Programs Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance Criteria or specific requirement: It is the Authority’s responsibility to establish and maintain systems of internal control over compliance that includes proper segregation of duties. Condition: The Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance to an appropriately low level. Context: While performing audit procedures, it was noted that the Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance with respect to compliance requirements related to eligibility and special tests and provisions. Cause: The Authority has not taken the appropriate steps to construct internal controls within their policies and procedures related to compliance with the Federal programs to the extent that the risk of noncompliance is reduced to an appropriately low level. Effect: As a result of the lack of segregation of duties and internal control, there were several compliance findings noted that resulted in material noncompliance with respect to eligibility and special tests and provisions. Repeat Finding: Yes; 2022-002. Recommendation: We recommend that the Authority’s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003: Income and Asset Verification Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: Income reported on the tenant assistance application was verified by the housing specialist by obtaining 3rd party verification of annual income. (3rd party verification includes direct confirmation from an employer, at least 4 paystubs, EIV report (required for 10/09 and later), SS award letter, printouts from Dept of Social Services for TANF, child support, etc.) (24 CFR 985.516). Assets reported on the tenant assistance application were verified by the leasing specialist by obtaining 3rd party verification of assets. If the tenant listed bank accounts, the PHA must obtain account balances from the bank or copies of bank statements. If the tenant receives SS income or wages, look at these forms to see if there is any indication of direct deposit. If so, the PHA should have gotten bank statements). (24 CFR 985.516). HAP/TAP was properly calculated using all verified information from above and was inputted into the HUD 50058 calculation. If the income reported is not correct per #2 above or there was no 3rd party verification of assets, this is incorrect as well. Condition: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: Known - Unknown | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not maintain evidence of completion of income verification as a part of the annual re-examination and six (6) tenant files did not contain third party verification of assets. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 985.516. Repeat Finding: Yes; 2022-003 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004: Reasonable Rent Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHS must maintain records to document the bases for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, five (5) tenant files did not include documentation of performance of rent reasonableness prior to the lease date. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005: Utility Allowance Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised. Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not include proper documentation of utility allowance. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006: Annual Inspections Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Authority failed to comply with the requirements of the annual HQS inspection as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-005 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 007: Housing Quality Standards (HQS) Enforcement Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (HQS), the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: During our testing, we noted the Authority failed to comply with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of twenty one (21) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-006 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 008: Financial Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA is required to submit an unaudited Financial Information within 2 months and audited annual Financial Report within 9 months to HUD electronically via the FASS-PH system. Condition: During our testing, we noted the Authority failed to comply with the requirements of the financial reporting as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: Unaudited REAC was submitted after the required two-month deadline. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002: Segregation of Duties - Compliance Federal agency: All Programs Federal program title: All Programs Assistance Listing No.: All Programs Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance Criteria or specific requirement: It is the Authority’s responsibility to establish and maintain systems of internal control over compliance that includes proper segregation of duties. Condition: The Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance to an appropriately low level. Context: While performing audit procedures, it was noted that the Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance with respect to compliance requirements related to eligibility and special tests and provisions. Cause: The Authority has not taken the appropriate steps to construct internal controls within their policies and procedures related to compliance with the Federal programs to the extent that the risk of noncompliance is reduced to an appropriately low level. Effect: As a result of the lack of segregation of duties and internal control, there were several compliance findings noted that resulted in material noncompliance with respect to eligibility and special tests and provisions. Repeat Finding: Yes; 2022-002. Recommendation: We recommend that the Authority’s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003: Income and Asset Verification Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: Income reported on the tenant assistance application was verified by the housing specialist by obtaining 3rd party verification of annual income. (3rd party verification includes direct confirmation from an employer, at least 4 paystubs, EIV report (required for 10/09 and later), SS award letter, printouts from Dept of Social Services for TANF, child support, etc.) (24 CFR 985.516). Assets reported on the tenant assistance application were verified by the leasing specialist by obtaining 3rd party verification of assets. If the tenant listed bank accounts, the PHA must obtain account balances from the bank or copies of bank statements. If the tenant receives SS income or wages, look at these forms to see if there is any indication of direct deposit. If so, the PHA should have gotten bank statements). (24 CFR 985.516). HAP/TAP was properly calculated using all verified information from above and was inputted into the HUD 50058 calculation. If the income reported is not correct per #2 above or there was no 3rd party verification of assets, this is incorrect as well. Condition: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: Known - Unknown | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not maintain evidence of completion of income verification as a part of the annual re-examination and six (6) tenant files did not contain third party verification of assets. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 985.516. Repeat Finding: Yes; 2022-003 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004: Reasonable Rent Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHS must maintain records to document the bases for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, five (5) tenant files did not include documentation of performance of rent reasonableness prior to the lease date. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005: Utility Allowance Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised. Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not include proper documentation of utility allowance. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006: Annual Inspections Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Authority failed to comply with the requirements of the annual HQS inspection as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-005 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 007: Housing Quality Standards (HQS) Enforcement Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (HQS), the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: During our testing, we noted the Authority failed to comply with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of twenty one (21) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-006 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 008: Financial Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA is required to submit an unaudited Financial Information within 2 months and audited annual Financial Report within 9 months to HUD electronically via the FASS-PH system. Condition: During our testing, we noted the Authority failed to comply with the requirements of the financial reporting as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: Unaudited REAC was submitted after the required two-month deadline. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002: Segregation of Duties - Compliance Federal agency: All Programs Federal program title: All Programs Assistance Listing No.: All Programs Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance Criteria or specific requirement: It is the Authority’s responsibility to establish and maintain systems of internal control over compliance that includes proper segregation of duties. Condition: The Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance to an appropriately low level. Context: While performing audit procedures, it was noted that the Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance with respect to compliance requirements related to eligibility and special tests and provisions. Cause: The Authority has not taken the appropriate steps to construct internal controls within their policies and procedures related to compliance with the Federal programs to the extent that the risk of noncompliance is reduced to an appropriately low level. Effect: As a result of the lack of segregation of duties and internal control, there were several compliance findings noted that resulted in material noncompliance with respect to eligibility and special tests and provisions. Repeat Finding: Yes; 2022-002. Recommendation: We recommend that the Authority’s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003: Income and Asset Verification Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: Income reported on the tenant assistance application was verified by the housing specialist by obtaining 3rd party verification of annual income. (3rd party verification includes direct confirmation from an employer, at least 4 paystubs, EIV report (required for 10/09 and later), SS award letter, printouts from Dept of Social Services for TANF, child support, etc.) (24 CFR 985.516). Assets reported on the tenant assistance application were verified by the leasing specialist by obtaining 3rd party verification of assets. If the tenant listed bank accounts, the PHA must obtain account balances from the bank or copies of bank statements. If the tenant receives SS income or wages, look at these forms to see if there is any indication of direct deposit. If so, the PHA should have gotten bank statements). (24 CFR 985.516). HAP/TAP was properly calculated using all verified information from above and was inputted into the HUD 50058 calculation. If the income reported is not correct per #2 above or there was no 3rd party verification of assets, this is incorrect as well. Condition: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: Known - Unknown | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not maintain evidence of completion of income verification as a part of the annual re-examination and six (6) tenant files did not contain third party verification of assets. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 985.516. Repeat Finding: Yes; 2022-003 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004: Reasonable Rent Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHS must maintain records to document the bases for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, five (5) tenant files did not include documentation of performance of rent reasonableness prior to the lease date. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005: Utility Allowance Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised. Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not include proper documentation of utility allowance. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006: Annual Inspections Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Authority failed to comply with the requirements of the annual HQS inspection as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-005 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 007: Housing Quality Standards (HQS) Enforcement Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (HQS), the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: During our testing, we noted the Authority failed to comply with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of twenty one (21) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-006 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 008: Financial Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA is required to submit an unaudited Financial Information within 2 months and audited annual Financial Report within 9 months to HUD electronically via the FASS-PH system. Condition: During our testing, we noted the Authority failed to comply with the requirements of the financial reporting as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: Unaudited REAC was submitted after the required two-month deadline. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.