2023-001 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 2022-002 from March 31, 2022 (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 reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024.
Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified 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.
2023-004 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
This is a repeat finding of 2022-005 from March 31, 2022
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 the utility ledger.
Effect: The Authority did not retain 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 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 retain the utility ledger. We will retain the utility ledger for each fiscal year under audit.
2023-001 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 2022-002 from March 31, 2022 (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 reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024.
Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified 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.
2023-002 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance
This is a repeat finding of 2022-003, reported as a Material Weakness from March 31, 2022 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o General assistance income was included in income when it should have been excluded. Correcting this error would increase the HAP rent from $958 to $1,027.
o One missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The tenant’s medical expense was misreported on the 50058. However, the error had no effect on the HAP rent.
• 1 tenant file error for one missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $846 to $724:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
o Miscalculation of the tenant’s annual unreimbursed childcare costs reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file had the following errors and correcting the errors would have no effect on the HAP rent:
o Food assistance was included as income when it should have been excluded.
o The tenant’s utility allowance was misreported on the 50058.
• 1 tenant file error where the tenant’s utility allowance was misreported and correcting the error would decrease the HAP rent from $1,198 to $1,183.
• 1 tenant fille error where the tenant did not sign the lease agreement.
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.
2023-003 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
This is a repeat finding of 2022-004 from March 31, 2022
Condition: 14 out of 137 new admissions were selected for testing, but testing was suspended after testing 8 files due to the number of errors. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o The tenant signed the request for tenancy approval form after the voucher expiration date.
o The Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenant was not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant and landlord signed the request for tenancy approval form after the voucher expiration date.
• 5 tenant file errors where the Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenants were not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant was selected from the tenant-based mainstream waiting list. 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.
2023-001 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 2022-002 from March 31, 2022 (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 reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024.
Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified 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.
2023-002 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance
This is a repeat finding of 2022-003, reported as a Material Weakness from March 31, 2022 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o General assistance income was included in income when it should have been excluded. Correcting this error would increase the HAP rent from $958 to $1,027.
o One missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The tenant’s medical expense was misreported on the 50058. However, the error had no effect on the HAP rent.
• 1 tenant file error for one missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $846 to $724:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
o Miscalculation of the tenant’s annual unreimbursed childcare costs reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file had the following errors and correcting the errors would have no effect on the HAP rent:
o Food assistance was included as income when it should have been excluded.
o The tenant’s utility allowance was misreported on the 50058.
• 1 tenant file error where the tenant’s utility allowance was misreported and correcting the error would decrease the HAP rent from $1,198 to $1,183.
• 1 tenant fille error where the tenant did not sign the lease agreement.
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.
2023-003 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
This is a repeat finding of 2022-004 from March 31, 2022
Condition: 14 out of 137 new admissions were selected for testing, but testing was suspended after testing 8 files due to the number of errors. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o The tenant signed the request for tenancy approval form after the voucher expiration date.
o The Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenant was not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant and landlord signed the request for tenancy approval form after the voucher expiration date.
• 5 tenant file errors where the Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenants were not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant was selected from the tenant-based mainstream waiting list. 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.
2023-001 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 2022-002 from March 31, 2022 (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 reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024.
Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified 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.
2023-002 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance
This is a repeat finding of 2022-003, reported as a Material Weakness from March 31, 2022 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o General assistance income was included in income when it should have been excluded. Correcting this error would increase the HAP rent from $958 to $1,027.
o One missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The tenant’s medical expense was misreported on the 50058. However, the error had no effect on the HAP rent.
• 1 tenant file error for one missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $846 to $724:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
o Miscalculation of the tenant’s annual unreimbursed childcare costs reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file had the following errors and correcting the errors would have no effect on the HAP rent:
o Food assistance was included as income when it should have been excluded.
o The tenant’s utility allowance was misreported on the 50058.
• 1 tenant file error where the tenant’s utility allowance was misreported and correcting the error would decrease the HAP rent from $1,198 to $1,183.
• 1 tenant fille error where the tenant did not sign the lease agreement.
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.
2023-003 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
This is a repeat finding of 2022-004 from March 31, 2022
Condition: 14 out of 137 new admissions were selected for testing, but testing was suspended after testing 8 files due to the number of errors. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o The tenant signed the request for tenancy approval form after the voucher expiration date.
o The Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenant was not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant and landlord signed the request for tenancy approval form after the voucher expiration date.
• 5 tenant file errors where the Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenants were not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant was selected from the tenant-based mainstream waiting list. 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.
2023-001 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 2022-002 from March 31, 2022 (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 reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024.
Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified 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.
2023-004 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
This is a repeat finding of 2022-005 from March 31, 2022
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 the utility ledger.
Effect: The Authority did not retain 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 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 retain the utility ledger. We will retain the utility ledger for each fiscal year under audit.
2023-001 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 2022-002 from March 31, 2022 (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 reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024.
Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified 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.
2023-002 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance
This is a repeat finding of 2022-003, reported as a Material Weakness from March 31, 2022 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o General assistance income was included in income when it should have been excluded. Correcting this error would increase the HAP rent from $958 to $1,027.
o One missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The tenant’s medical expense was misreported on the 50058. However, the error had no effect on the HAP rent.
• 1 tenant file error for one missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $846 to $724:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
o Miscalculation of the tenant’s annual unreimbursed childcare costs reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file had the following errors and correcting the errors would have no effect on the HAP rent:
o Food assistance was included as income when it should have been excluded.
o The tenant’s utility allowance was misreported on the 50058.
• 1 tenant file error where the tenant’s utility allowance was misreported and correcting the error would decrease the HAP rent from $1,198 to $1,183.
• 1 tenant fille error where the tenant did not sign the lease agreement.
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.
2023-003 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
This is a repeat finding of 2022-004 from March 31, 2022
Condition: 14 out of 137 new admissions were selected for testing, but testing was suspended after testing 8 files due to the number of errors. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o The tenant signed the request for tenancy approval form after the voucher expiration date.
o The Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenant was not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant and landlord signed the request for tenancy approval form after the voucher expiration date.
• 5 tenant file errors where the Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenants were not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant was selected from the tenant-based mainstream waiting list. 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.
2023-001 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 2022-002 from March 31, 2022 (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 reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024.
Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified 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.
2023-002 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance
This is a repeat finding of 2022-003, reported as a Material Weakness from March 31, 2022 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o General assistance income was included in income when it should have been excluded. Correcting this error would increase the HAP rent from $958 to $1,027.
o One missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The tenant’s medical expense was misreported on the 50058. However, the error had no effect on the HAP rent.
• 1 tenant file error for one missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $846 to $724:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
o Miscalculation of the tenant’s annual unreimbursed childcare costs reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file had the following errors and correcting the errors would have no effect on the HAP rent:
o Food assistance was included as income when it should have been excluded.
o The tenant’s utility allowance was misreported on the 50058.
• 1 tenant file error where the tenant’s utility allowance was misreported and correcting the error would decrease the HAP rent from $1,198 to $1,183.
• 1 tenant fille error where the tenant did not sign the lease agreement.
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.
2023-003 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
This is a repeat finding of 2022-004 from March 31, 2022
Condition: 14 out of 137 new admissions were selected for testing, but testing was suspended after testing 8 files due to the number of errors. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o The tenant signed the request for tenancy approval form after the voucher expiration date.
o The Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenant was not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant and landlord signed the request for tenancy approval form after the voucher expiration date.
• 5 tenant file errors where the Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenants were not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant was selected from the tenant-based mainstream waiting list. 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.
2023-001 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 2022-002 from March 31, 2022 (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 reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024.
Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified 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.
2023-002 Eligibility – Tenant Files
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance
This is a repeat finding of 2022-003, reported as a Material Weakness from March 31, 2022 (initially occurred as Finding 2021-003, Significant Deficiency)
Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o General assistance income was included in income when it should have been excluded. Correcting this error would increase the HAP rent from $958 to $1,027.
o One missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors:
o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens.
o The tenant’s medical expense was misreported on the 50058. However, the error had no effect on the HAP rent.
• 1 tenant file error for one missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen.
• 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $846 to $724:
o Miscalculation of social security income reported on the 50058.
o Miscalculation of medical expense reported on the 50058.
o Miscalculation of the tenant’s annual unreimbursed childcare costs reported on the 50058.
• 1 tenant file error where a member of the household over the age of 18 did not sign the 9886.
• 1 tenant file had the following errors and correcting the errors would have no effect on the HAP rent:
o Food assistance was included as income when it should have been excluded.
o The tenant’s utility allowance was misreported on the 50058.
• 1 tenant file error where the tenant’s utility allowance was misreported and correcting the error would decrease the HAP rent from $1,198 to $1,183.
• 1 tenant fille error where the tenant did not sign the lease agreement.
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.
2023-003 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
This is a repeat finding of 2022-004 from March 31, 2022
Condition: 14 out of 137 new admissions were selected for testing, but testing was suspended after testing 8 files due to the number of errors. Exceptions were noted as follows:
• 1 tenant file had the following errors:
o The tenant signed the request for tenancy approval form after the voucher expiration date.
o The Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenant was not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant and landlord signed the request for tenancy approval form after the voucher expiration date.
• 5 tenant file errors where the Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenants were not admitted properly into the Section 8 program.
• 1 tenant file error where the tenant was selected from the tenant-based mainstream waiting list. 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.