U.S. Department of Housing and Urban Development ‐ CFDA #14.871
Section 8 Housing Choice Vouchers
Applicable Federal Award Number and Year – Section 8 Housing Choice Vouchers ‐ 2022
Special Tests and Provisions – Reasonable Rent
Significant Deficiency in Internal Control over Compliance
Criteria – The Program requires the Authority to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units at the time of initial leasing and during the term of the HAP contract.
Condition – During our testing of reasonable rent, we identified 10 instances when the Authority did not maintain records to document the basis for the determination that rent to owner is reasonable rent.
Questioned Costs – None Reported.
Context/Sampling – A non‐statistical sample of 15 rent reasonableness verifications were selected for testing. 10 out of the 15 rent reasonableness verifications did not have documentation of the basis for the determination that rent to owner is reasonable rent.
Effect – Failure to implement and maintain a proper control process could result in over payment of HAP.
Cause – The Authority has experienced significant staff turnover and due to a lack of oversight the appropriate steps were not documented to ensure compliance with the program requirements.
Repeat Finding from Prior Year – No.
Recommendation – The Authority should ensure that processes are implemented to ensure compliance with program requirements for reasonable rent.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.850
Public and Indian Housing
Applicable Federal Award Number and Year – Public and Indian Housing ‐ 2022
Eligibility
Material Weakness in Internal Control over Compliance
Criteria – The Program requires the Authority to determine eligibility of participants of the program through annual and interim review of participant information.
Condition – During our testing, we identified an error in the tenant rent calculation for 2 individuals that were not detected by the Authority’s internal controls. In addition, there was no review of any of the rent calculations by another individual.
Questioned Costs – None Reported.
Context/Sampling – A non‐statistical sample of 60 participants were selected for testing. 2 out of the 60 tenant files had an incorrect rent calculation.
Effect – Failure to implement and maintain a proper control process could result in incorrect calculations of income, which could cause errors in eligibility determinations.
Cause – The Authority has experienced significant staff turnover and the Authority’s controls are currently not adequately designed and operating.
Repeat Finding from Prior Year – Yes.
Recommendation – The Authority should implement controls to ensure eligibility requirements are being followed and that there is a review of tenant eligibility calculations by another individual.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.850
Public and Indian Housing
Applicable Federal Award Number and Year – Public and Indian Housing ‐ 2022
Procurement, Suspension and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria – Non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – During our testing, we observed that the Authority had not retained documentation that they had performed a search for suspension and debarment. Upon our search, none of the vendors were suspended or debarred.
Questioned Costs – None Reported.
Context/Sampling – A non‐statistical sample of 7 expenditures were selected for testing. 7 out of the 7 transactions did not have proper documentation that the vendor was not suspended or disbarred.
Effect – Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Cause – Due to a lack of oversight, the Authority did not retain documentation that they had performed a search for suspension and debarment.
Repeat Finding from Prior Year – Yes.
Recommendation – The Authority should maintain documentation showing they performed a search for suspension and debarment and proper research for sole source determinations.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.872
Capital Fund Program
Applicable Federal Award Number and Year – Capital Fund Program ‐ 2022
Procurement, Suspension and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria – Non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – During our testing of suspension and debarment, we observed that the Authority had not retained documentation that they had performed a search for suspension and debarment. Upon our search, none of the vendors were suspended or debarred.
Questioned Costs – None Reported.
Context/Sampling – A non‐statistical sample of 6 expenditures were selected for testing. 3 out of the 6 transactions did not have proper documentation that the vendor was not suspended or disbarred.
Effect – Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred.
Cause – Due to a lack of oversight, the Authority did not retain documentation that they had performed a search for suspension and debarment.
Repeat Finding from Prior Year – Yes.
Recommendation – The Authority should maintain documentation showing they performed a search for suspension and debarment.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.872
Capital Fund Program
Applicable Federal Award Number and Year – Capital Fund Program ‐ 2022
Special Tests and Provisions – Capital Funds for Operating Costs
Significant Deficiency in Internal Control over Compliance
Criteria – A complete system of internal control contemplates for the development of a process to track and monitor the obligation and expenditure of program funds to ensure they are within program guidelines and requirements.
Condition – During our testing it was determined there was no consistent, documented process to ensure the timely obligation and expenditure of program funds to remain in compliance.
Questioned Costs – None Reported.
Context/Sampling – Not Applicable.
Effect – Failure to implement and maintain a proper control process could result in failure to meet the obligation and expenditure requirements of the program, resulting in the loss of funding.
Cause – Due to a lack of oversight, the Authority did not retain documentation that they had monitored the various program requirements to ensure compliance.
Repeat Finding from Prior Year – Yes.
Recommendation – The Authority should develop a process and maintain documentation showing they are consistently monitoring the obligation and expenditure requirements of the program.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.872
Capital Fund Program
Applicable Federal Award Number and Year – Capital Fund Program ‐ 2022
Special Tests and Provisions – Environmental Reviews
Significant Deficiency in Internal Control over Compliance
Criteria – The Program requires an environmental review must be completed every 5 years for any project or activities before a PHA may acquire, rehabilitate, convert, lease, repair or construct property, or commit HUD or local funds at an assisted or to‐be‐assisted site.
Condition – The Authority has not had an environmental review completed for 3 of the 4 projects.
Questioned Costs – None Reported.
Context/Sampling – N/A
Effect – Failure to implement and maintain a proper control process resulted in environmental reviews not being completed on 3 of the 4 projects.
Cause – The Authority has experienced significant staff turnover and the Authority’s controls are currently not adequately designed and operating.
Repeat Finding from Prior Year – No.
Recommendation – The Authority should implement controls to ensure that an environmental review is completed for all projects at least every 5 years.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.871
Section 8 Housing Choice Vouchers
Applicable Federal Award Number and Year – Section 8 Housing Choice Vouchers ‐ 2022
Special Tests and Provisions – Reasonable Rent
Significant Deficiency in Internal Control over Compliance
Criteria – The Program requires the Authority to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units at the time of initial leasing and during the term of the HAP contract.
Condition – During our testing of reasonable rent, we identified 10 instances when the Authority did not maintain records to document the basis for the determination that rent to owner is reasonable rent.
Questioned Costs – None Reported.
Context/Sampling – A non‐statistical sample of 15 rent reasonableness verifications were selected for testing. 10 out of the 15 rent reasonableness verifications did not have documentation of the basis for the determination that rent to owner is reasonable rent.
Effect – Failure to implement and maintain a proper control process could result in over payment of HAP.
Cause – The Authority has experienced significant staff turnover and due to a lack of oversight the appropriate steps were not documented to ensure compliance with the program requirements.
Repeat Finding from Prior Year – No.
Recommendation – The Authority should ensure that processes are implemented to ensure compliance with program requirements for reasonable rent.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.850
Public and Indian Housing
Applicable Federal Award Number and Year – Public and Indian Housing ‐ 2022
Eligibility
Material Weakness in Internal Control over Compliance
Criteria – The Program requires the Authority to determine eligibility of participants of the program through annual and interim review of participant information.
Condition – During our testing, we identified an error in the tenant rent calculation for 2 individuals that were not detected by the Authority’s internal controls. In addition, there was no review of any of the rent calculations by another individual.
Questioned Costs – None Reported.
Context/Sampling – A non‐statistical sample of 60 participants were selected for testing. 2 out of the 60 tenant files had an incorrect rent calculation.
Effect – Failure to implement and maintain a proper control process could result in incorrect calculations of income, which could cause errors in eligibility determinations.
Cause – The Authority has experienced significant staff turnover and the Authority’s controls are currently not adequately designed and operating.
Repeat Finding from Prior Year – Yes.
Recommendation – The Authority should implement controls to ensure eligibility requirements are being followed and that there is a review of tenant eligibility calculations by another individual.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.850
Public and Indian Housing
Applicable Federal Award Number and Year – Public and Indian Housing ‐ 2022
Procurement, Suspension and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria – Non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – During our testing, we observed that the Authority had not retained documentation that they had performed a search for suspension and debarment. Upon our search, none of the vendors were suspended or debarred.
Questioned Costs – None Reported.
Context/Sampling – A non‐statistical sample of 7 expenditures were selected for testing. 7 out of the 7 transactions did not have proper documentation that the vendor was not suspended or disbarred.
Effect – Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Cause – Due to a lack of oversight, the Authority did not retain documentation that they had performed a search for suspension and debarment.
Repeat Finding from Prior Year – Yes.
Recommendation – The Authority should maintain documentation showing they performed a search for suspension and debarment and proper research for sole source determinations.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.872
Capital Fund Program
Applicable Federal Award Number and Year – Capital Fund Program ‐ 2022
Procurement, Suspension and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria – Non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – During our testing of suspension and debarment, we observed that the Authority had not retained documentation that they had performed a search for suspension and debarment. Upon our search, none of the vendors were suspended or debarred.
Questioned Costs – None Reported.
Context/Sampling – A non‐statistical sample of 6 expenditures were selected for testing. 3 out of the 6 transactions did not have proper documentation that the vendor was not suspended or disbarred.
Effect – Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred.
Cause – Due to a lack of oversight, the Authority did not retain documentation that they had performed a search for suspension and debarment.
Repeat Finding from Prior Year – Yes.
Recommendation – The Authority should maintain documentation showing they performed a search for suspension and debarment.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.872
Capital Fund Program
Applicable Federal Award Number and Year – Capital Fund Program ‐ 2022
Special Tests and Provisions – Capital Funds for Operating Costs
Significant Deficiency in Internal Control over Compliance
Criteria – A complete system of internal control contemplates for the development of a process to track and monitor the obligation and expenditure of program funds to ensure they are within program guidelines and requirements.
Condition – During our testing it was determined there was no consistent, documented process to ensure the timely obligation and expenditure of program funds to remain in compliance.
Questioned Costs – None Reported.
Context/Sampling – Not Applicable.
Effect – Failure to implement and maintain a proper control process could result in failure to meet the obligation and expenditure requirements of the program, resulting in the loss of funding.
Cause – Due to a lack of oversight, the Authority did not retain documentation that they had monitored the various program requirements to ensure compliance.
Repeat Finding from Prior Year – Yes.
Recommendation – The Authority should develop a process and maintain documentation showing they are consistently monitoring the obligation and expenditure requirements of the program.
Views of Responsible Officials – Management agrees with the finding.
U.S. Department of Housing and Urban Development ‐ CFDA #14.872
Capital Fund Program
Applicable Federal Award Number and Year – Capital Fund Program ‐ 2022
Special Tests and Provisions – Environmental Reviews
Significant Deficiency in Internal Control over Compliance
Criteria – The Program requires an environmental review must be completed every 5 years for any project or activities before a PHA may acquire, rehabilitate, convert, lease, repair or construct property, or commit HUD or local funds at an assisted or to‐be‐assisted site.
Condition – The Authority has not had an environmental review completed for 3 of the 4 projects.
Questioned Costs – None Reported.
Context/Sampling – N/A
Effect – Failure to implement and maintain a proper control process resulted in environmental reviews not being completed on 3 of the 4 projects.
Cause – The Authority has experienced significant staff turnover and the Authority’s controls are currently not adequately designed and operating.
Repeat Finding from Prior Year – No.
Recommendation – The Authority should implement controls to ensure that an environmental review is completed for all projects at least every 5 years.
Views of Responsible Officials – Management agrees with the finding.