Audit 322620

FY End
2023-12-31
Total Expended
$9.90M
Findings
6
Programs
5
Year: 2023 Accepted: 2024-09-30
Auditor: Cohnreznick LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
499774 2023-001 Significant Deficiency - N
499775 2023-002 Material Weakness - E
499776 2023-003 Material Weakness - N
1076216 2023-001 Significant Deficiency - N
1076217 2023-002 Material Weakness - E
1076218 2023-003 Material Weakness - N

Programs

ALN Program Spent Major Findings
14.871 Section 8 Housing Choice Vouchers $7.26M Yes 1
14.850 Public Housing Operating Fund $1.44M Yes 2
14.872 Public Housing Capital Fund $1.09M Yes 0
14.896 Family Self-Sufficiency Program $86,408 - 0
14.870 Resident Opportunity and Supportive Services - Service Coordinators $29,119 - 0

Contacts

Name Title Type
LD8ST9PJBJ13 Derrick Bryant Auditee
2038691138 Melissa Ferrucci Auditor
No contacts on file

Notes to SEFA

Title: Note 1 - Basis of presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. 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. De Minimis Rate Used: N Rate Explanation: Greenwich Communities has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal award activity of Greenwich Communities under programs of the federal government for the year ended December 31, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance"). Because the Schedule presents only a selected portion of the operations of Greenwich Communities, it is not intended to and does not present the financial position, changes in net position, or cash flows of Greenwich Communities.
Title: Note 2 - Summary of significant accounting policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. 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. De Minimis Rate Used: N Rate Explanation: Greenwich Communities has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. 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.
Title: Note 3 - Indirect cost rate Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. 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. De Minimis Rate Used: N Rate Explanation: Greenwich Communities has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Greenwich Communities has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: Note 4 - Subrecipients Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. 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. De Minimis Rate Used: N Rate Explanation: Greenwich Communities has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. There were no monies passed through to subrecipients.

Finding Details

2023-001 – Special Tests and Provisions: Housing Voucher Cluster (FALN #14.871) Significant Deficiency in Internal Control; Material Noncompliance Criteria HUD regulations of PHA Approval of Assisted Tenancy (24 CFR § 982.305), and PHA Unit Inspection (24 CFR § 982.405) require the PHA to inspect the unit at least annually and in accordance with PHA’s policy. Condition The results of our testing indicated that certain items were unable to be located in the file, as follows: • In two instances, annual inspections of tenant units were not completed. Questioned Costs Not determinable. Context We selected a sample of 40 files for review. Our sample was a statistically valid sample. Effect or Possible Effect We were unable to determinate if Greenwich Communities was performing annual tenant unit inspections as required. Cause The cause is unknown. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that Greenwich Communities improve its internal processes to ensure tenant files contain the required documentation, and annual tenant unit inspections are performed timely. Greenwich Communities’ Response Management concurs with the finding and has established plans to provide additional training and review of tenant files going forward to ensure required inspections are performed and documentation is included in tenant files. Management will have certification schedules printed monthly, reviewed and emailed to the third-party contractor who was hired to complete the annual inspections. In addition, all tenant files will be reviewed by management and approved.
2023-002 - Eligibility: Public Housing Operating Fund (FALN #14.850) Material Weakness in Internal Control; Material Noncompliance Criteria HUD regulations of Annual Income (24 CFR § 5.609), Eligible Family Status (24 CFR § 5.403), Citizenship and Eligible Immigrant Status (24 CFR § 5.506) and Disclosure of Social Security Numbers (24 CFR § 5.216) require the collection and retention of certain tenant information to document the eligibility determination for each recipient. Condition The results of our testing indicated that certain items were unable to be located in the file, as follows: • In ten instances, the Enterprise Income Verification (EIV) was not performed annually. • In three instances, the annual recertification was not performed timely. • In two instances, EIV was performed, however was not performed timely. • In one instance, the social security card was missing from the tenant file. • In one instance, the approval for tenant's background check was missing from the tenant file. • In two instances, HUD Form 9887 was missing from the tenant's file. Questioned Costs Not determinable. Context We selected a sample of 40 files for review. Our sample was a statistically valid sample. Effect or Possible Effect The tenant file documentation was incomplete, and in certain instances, we were not able to determine if Greenwich Communities’ income verification was done accurately. Cause The cause is unknown. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that Greenwich Communities improve its internal processes to ensure tenant files contain the required documentation. Greenwich Communities’ Response Management concurs with the finding and has established plans to provide additional training and review of tenant files going forward by the Director of Housing Management to ensure required tenant certifications are performed timely and completely, and all required tenant certification documentation is included in tenant files.
2023-003 - Special Tests: Public Housing Operating Fund (FALN #14.850) Material Weakness in Internal Control; Material Weakness Criteria HUD regulations for Public Housing Waiting List (24 CFR § 960.202 through 960.206), require the public housing authority to establish and adopt written policies for admission of tenants. The Public Housing Authority tenant selection policies must include requirements for applications and waiting lists, description of policies for selection of applicants from the waiting lists and policies for verification to acceptance or rejections of an applicant. Condition The results of our testing indicated that the waitlist has not been updated to include new applicants since April 2023. Questioned Costs Not determinable. Context We selected a sample of 11 additions to the waitlist and 18 removals from the waitlist prior to April 2023. Our sample was a statistically valid sample. Effect or Possible Effect The waiting list was incomplete and, therefore, we were not able to determine if participants were being housed in the correct manner. Cause The cause is unknown. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that Greenwich Communities improve its internal processes to ensure all applicants are timely entered into the waiting list. Greenwich Communities’ Response Management concurs with the finding and has updated the tenant waiting list for all projects in the Low Income Public Housing program. In addition, management established plans to provide additional training and review of the waiting lists going forward by the Director of Housing Management to ensure that waiting lists are maintained in accordance with the applicable regulations.
2023-001 – Special Tests and Provisions: Housing Voucher Cluster (FALN #14.871) Significant Deficiency in Internal Control; Material Noncompliance Criteria HUD regulations of PHA Approval of Assisted Tenancy (24 CFR § 982.305), and PHA Unit Inspection (24 CFR § 982.405) require the PHA to inspect the unit at least annually and in accordance with PHA’s policy. Condition The results of our testing indicated that certain items were unable to be located in the file, as follows: • In two instances, annual inspections of tenant units were not completed. Questioned Costs Not determinable. Context We selected a sample of 40 files for review. Our sample was a statistically valid sample. Effect or Possible Effect We were unable to determinate if Greenwich Communities was performing annual tenant unit inspections as required. Cause The cause is unknown. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that Greenwich Communities improve its internal processes to ensure tenant files contain the required documentation, and annual tenant unit inspections are performed timely. Greenwich Communities’ Response Management concurs with the finding and has established plans to provide additional training and review of tenant files going forward to ensure required inspections are performed and documentation is included in tenant files. Management will have certification schedules printed monthly, reviewed and emailed to the third-party contractor who was hired to complete the annual inspections. In addition, all tenant files will be reviewed by management and approved.
2023-002 - Eligibility: Public Housing Operating Fund (FALN #14.850) Material Weakness in Internal Control; Material Noncompliance Criteria HUD regulations of Annual Income (24 CFR § 5.609), Eligible Family Status (24 CFR § 5.403), Citizenship and Eligible Immigrant Status (24 CFR § 5.506) and Disclosure of Social Security Numbers (24 CFR § 5.216) require the collection and retention of certain tenant information to document the eligibility determination for each recipient. Condition The results of our testing indicated that certain items were unable to be located in the file, as follows: • In ten instances, the Enterprise Income Verification (EIV) was not performed annually. • In three instances, the annual recertification was not performed timely. • In two instances, EIV was performed, however was not performed timely. • In one instance, the social security card was missing from the tenant file. • In one instance, the approval for tenant's background check was missing from the tenant file. • In two instances, HUD Form 9887 was missing from the tenant's file. Questioned Costs Not determinable. Context We selected a sample of 40 files for review. Our sample was a statistically valid sample. Effect or Possible Effect The tenant file documentation was incomplete, and in certain instances, we were not able to determine if Greenwich Communities’ income verification was done accurately. Cause The cause is unknown. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that Greenwich Communities improve its internal processes to ensure tenant files contain the required documentation. Greenwich Communities’ Response Management concurs with the finding and has established plans to provide additional training and review of tenant files going forward by the Director of Housing Management to ensure required tenant certifications are performed timely and completely, and all required tenant certification documentation is included in tenant files.
2023-003 - Special Tests: Public Housing Operating Fund (FALN #14.850) Material Weakness in Internal Control; Material Weakness Criteria HUD regulations for Public Housing Waiting List (24 CFR § 960.202 through 960.206), require the public housing authority to establish and adopt written policies for admission of tenants. The Public Housing Authority tenant selection policies must include requirements for applications and waiting lists, description of policies for selection of applicants from the waiting lists and policies for verification to acceptance or rejections of an applicant. Condition The results of our testing indicated that the waitlist has not been updated to include new applicants since April 2023. Questioned Costs Not determinable. Context We selected a sample of 11 additions to the waitlist and 18 removals from the waitlist prior to April 2023. Our sample was a statistically valid sample. Effect or Possible Effect The waiting list was incomplete and, therefore, we were not able to determine if participants were being housed in the correct manner. Cause The cause is unknown. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that Greenwich Communities improve its internal processes to ensure all applicants are timely entered into the waiting list. Greenwich Communities’ Response Management concurs with the finding and has updated the tenant waiting list for all projects in the Low Income Public Housing program. In addition, management established plans to provide additional training and review of the waiting lists going forward by the Director of Housing Management to ensure that waiting lists are maintained in accordance with the applicable regulations.