Audit 333618

2024 – 001 – HCVP Housing Quality Standards and Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $34,388 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following: -4 files where abatement ought to have been implemented, but records could not be located. -11 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: -43 instances where the annual inspection was not performed in a timely manner and the Comision failed to enforce the regulations Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 002 – HCVP Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: As a condition of admission or continued occupancy, the PHA must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.601 et seq., 5.609, 960.253, 960.255 and 960.259). 24 CFR section 960.259 states that for both family income examinations and reexaminations, the PHA must obtain and document in the family file third-party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. 24 CFR sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259 state that the Commission must determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR part 5, subpart F. 24 CFR sections 5.230, 5.609, and 960.259 state that as a condition of admission or continued occupancy, the Commission must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50058. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 001 – HCVP Housing Quality Standards and Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $34,388 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following: -4 files where abatement ought to have been implemented, but records could not be located. -11 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: -43 instances where the annual inspection was not performed in a timely manner and the Comision failed to enforce the regulations Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 002 – HCVP Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: As a condition of admission or continued occupancy, the PHA must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.601 et seq., 5.609, 960.253, 960.255 and 960.259). 24 CFR section 960.259 states that for both family income examinations and reexaminations, the PHA must obtain and document in the family file third-party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. 24 CFR sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259 state that the Commission must determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR part 5, subpart F. 24 CFR sections 5.230, 5.609, and 960.259 state that as a condition of admission or continued occupancy, the Commission must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50058. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 001 – HCVP Housing Quality Standards and Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $34,388 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following: -4 files where abatement ought to have been implemented, but records could not be located. -11 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: -43 instances where the annual inspection was not performed in a timely manner and the Comision failed to enforce the regulations Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 002 – HCVP Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: As a condition of admission or continued occupancy, the PHA must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.601 et seq., 5.609, 960.253, 960.255 and 960.259). 24 CFR section 960.259 states that for both family income examinations and reexaminations, the PHA must obtain and document in the family file third-party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. 24 CFR sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259 state that the Commission must determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR part 5, subpart F. 24 CFR sections 5.230, 5.609, and 960.259 state that as a condition of admission or continued occupancy, the Commission must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50058. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 003 – PBRA/MOD Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: $21,838 Context: Testing of 60 tenant files for eligibility revealed that 38 files had the following exceptions: -26 files were missing the application which includes signoff from the program specialist -28 files were missing documentation needed to support and recalculate total income per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the asset total per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the expenses total per HUD-50058/HUD-50059 -3 files where the annual examination was not processed within 12-month regulatory period -34 files that were missing the recertification checklist as part of their internal controls Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 004 – PBRA/MOD Housing Quality Standards Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that inspection requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 60 PBRA tenant files for annual inspection standards revealed the following exceptions: -40 instances where tenant files were missing one or more inspections and when inspections were included, it was indeterminable whether they were within the regulatory period -26 files missing the letters sent to tenants informing them of the scheduled HQS inspections Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 005 – PBRA/MOD - Public Housing Information Center (PIC) & Tenant Rental Assistance Certification (TRACS) Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 4 files had the following exceptions: -2 files failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC -2 instances where the Authority failed to provide the TRACS submission Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 006 – PBRA/MOD – Contract Rent Change Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner applies or ensures annual adjustments to contract rents are applied. The HAP original term contract or renewal contract specifies the method to be used to determine rent adjustments. Adjustments must not result in material differences between rents charged for assisted units and comparable unassisted units except as those differences existed at contract execution. Special adjustments to contract rents, within the original contract term, may also be made to the extent deemed necessary by the PHA or HUD (24 CFR sections 880.609, 881.601, 882.410, 882.808(e), 883.701, 884.109, 886.112, 886.312(c) and Section 524 of Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA) Title V of the HUD Fiscal Year 1998 Appropriations Act, Pub. L. 105-65, as amended). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure rent changes were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 12 exceptions: - 12 files where the rent on the 50059 did not match the approved rent schedules Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over rent changes. Effect: The Commission is not in compliance with program requirements over rent changes. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 007 – PBRA/MOD – Utility Allowances Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner must (a) establish or ensure tenant utility allowances based on utility consumption and rate data for various sized units, structure types, and fuel types, (b) make an annual review of tenant utility allowances to determine their reasonableness, and (c) adjust the allowances, when appropriate (24 CFR sections 5.603, 880.610, 881.601, 882.510, 882.808(k), 883.701, 884.220, 886.126, and 886.326). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure utility allowances were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 6 exceptions: 6 files where the utility allowance on the 50058/50059 did not match the approved utility allowance Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over utility allowances. Effect: The Commission is not in compliance with program requirements over utility allowances. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 008 – PBRA/MOD – Vacant Units Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: The PHA or owner must reduce claims for assistance on vacant units under certain circumstances. However, there are instances where special claims are allowed for vacancy losses, unpaid rent, and tenant damages on eligible units (24 CFR sections 880.611, 881.601, 882.411, 882.808(f), 883.701, 884.106, 886.109, and 886.309). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure claims for assistance were terminated. Questioned costs: $15,963 Context: Testing of 11 tenant files revealed the following 2 exceptions: - 2 files where claims for assistance were not properly terminated Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over vacant units. Effect: The Commission is not in compliance with program requirements over vacant units. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 003 – PBRA/MOD Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: $21,838 Context: Testing of 60 tenant files for eligibility revealed that 38 files had the following exceptions: -26 files were missing the application which includes signoff from the program specialist -28 files were missing documentation needed to support and recalculate total income per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the asset total per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the expenses total per HUD-50058/HUD-50059 -3 files where the annual examination was not processed within 12-month regulatory period -34 files that were missing the recertification checklist as part of their internal controls Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 004 – PBRA/MOD Housing Quality Standards Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that inspection requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 60 PBRA tenant files for annual inspection standards revealed the following exceptions: -40 instances where tenant files were missing one or more inspections and when inspections were included, it was indeterminable whether they were within the regulatory period -26 files missing the letters sent to tenants informing them of the scheduled HQS inspections Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 005 – PBRA/MOD - Public Housing Information Center (PIC) & Tenant Rental Assistance Certification (TRACS) Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 4 files had the following exceptions: -2 files failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC -2 instances where the Authority failed to provide the TRACS submission Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 006 – PBRA/MOD – Contract Rent Change Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner applies or ensures annual adjustments to contract rents are applied. The HAP original term contract or renewal contract specifies the method to be used to determine rent adjustments. Adjustments must not result in material differences between rents charged for assisted units and comparable unassisted units except as those differences existed at contract execution. Special adjustments to contract rents, within the original contract term, may also be made to the extent deemed necessary by the PHA or HUD (24 CFR sections 880.609, 881.601, 882.410, 882.808(e), 883.701, 884.109, 886.112, 886.312(c) and Section 524 of Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA) Title V of the HUD Fiscal Year 1998 Appropriations Act, Pub. L. 105-65, as amended). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure rent changes were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 12 exceptions: - 12 files where the rent on the 50059 did not match the approved rent schedules Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over rent changes. Effect: The Commission is not in compliance with program requirements over rent changes. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 007 – PBRA/MOD – Utility Allowances Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner must (a) establish or ensure tenant utility allowances based on utility consumption and rate data for various sized units, structure types, and fuel types, (b) make an annual review of tenant utility allowances to determine their reasonableness, and (c) adjust the allowances, when appropriate (24 CFR sections 5.603, 880.610, 881.601, 882.510, 882.808(k), 883.701, 884.220, 886.126, and 886.326). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure utility allowances were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 6 exceptions: 6 files where the utility allowance on the 50058/50059 did not match the approved utility allowance Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over utility allowances. Effect: The Commission is not in compliance with program requirements over utility allowances. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 008 – PBRA/MOD – Vacant Units Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: The PHA or owner must reduce claims for assistance on vacant units under certain circumstances. However, there are instances where special claims are allowed for vacancy losses, unpaid rent, and tenant damages on eligible units (24 CFR sections 880.611, 881.601, 882.411, 882.808(f), 883.701, 884.106, 886.109, and 886.309). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure claims for assistance were terminated. Questioned costs: $15,963 Context: Testing of 11 tenant files revealed the following 2 exceptions: - 2 files where claims for assistance were not properly terminated Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over vacant units. Effect: The Commission is not in compliance with program requirements over vacant units. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 001 – HCVP Housing Quality Standards and Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $34,388 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following: -4 files where abatement ought to have been implemented, but records could not be located. -11 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: -43 instances where the annual inspection was not performed in a timely manner and the Comision failed to enforce the regulations Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 002 – HCVP Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: As a condition of admission or continued occupancy, the PHA must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.601 et seq., 5.609, 960.253, 960.255 and 960.259). 24 CFR section 960.259 states that for both family income examinations and reexaminations, the PHA must obtain and document in the family file third-party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. 24 CFR sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259 state that the Commission must determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR part 5, subpart F. 24 CFR sections 5.230, 5.609, and 960.259 state that as a condition of admission or continued occupancy, the Commission must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50058. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 001 – HCVP Housing Quality Standards and Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $34,388 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following: -4 files where abatement ought to have been implemented, but records could not be located. -11 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: -43 instances where the annual inspection was not performed in a timely manner and the Comision failed to enforce the regulations Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 002 – HCVP Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: As a condition of admission or continued occupancy, the PHA must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.601 et seq., 5.609, 960.253, 960.255 and 960.259). 24 CFR section 960.259 states that for both family income examinations and reexaminations, the PHA must obtain and document in the family file third-party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. 24 CFR sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259 state that the Commission must determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR part 5, subpart F. 24 CFR sections 5.230, 5.609, and 960.259 state that as a condition of admission or continued occupancy, the Commission must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50058. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 001 – HCVP Housing Quality Standards and Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $34,388 Context: Testing of 60 HCVP tenant files for failed inspection standards revealed the following: -4 files where abatement ought to have been implemented, but records could not be located. -11 instances where the authority did not perform the second inspection within 30 days Testing of 60 HCVP tenant files for annual inspection standards revealed the following: -43 instances where the annual inspection was not performed in a timely manner and the Comision failed to enforce the regulations Cause: The Authority does not have controls in place to ensure it’s meeting HQS requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 002 – HCVP Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: As a condition of admission or continued occupancy, the PHA must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.601 et seq., 5.609, 960.253, 960.255 and 960.259). 24 CFR section 960.259 states that for both family income examinations and reexaminations, the PHA must obtain and document in the family file third-party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. 24 CFR sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259 state that the Commission must determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR part 5, subpart F. 24 CFR sections 5.230, 5.609, and 960.259 state that as a condition of admission or continued occupancy, the Commission must require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 1 of 40 HCVP tenant files for eligibility standards revealed one file missing documentation needed to support and recalculate total income per HUD-50058. Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: No Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 003 – PBRA/MOD Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: $21,838 Context: Testing of 60 tenant files for eligibility revealed that 38 files had the following exceptions: -26 files were missing the application which includes signoff from the program specialist -28 files were missing documentation needed to support and recalculate total income per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the asset total per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the expenses total per HUD-50058/HUD-50059 -3 files where the annual examination was not processed within 12-month regulatory period -34 files that were missing the recertification checklist as part of their internal controls Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 004 – PBRA/MOD Housing Quality Standards Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that inspection requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 60 PBRA tenant files for annual inspection standards revealed the following exceptions: -40 instances where tenant files were missing one or more inspections and when inspections were included, it was indeterminable whether they were within the regulatory period -26 files missing the letters sent to tenants informing them of the scheduled HQS inspections Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 005 – PBRA/MOD - Public Housing Information Center (PIC) & Tenant Rental Assistance Certification (TRACS) Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 4 files had the following exceptions: -2 files failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC -2 instances where the Authority failed to provide the TRACS submission Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 006 – PBRA/MOD – Contract Rent Change Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner applies or ensures annual adjustments to contract rents are applied. The HAP original term contract or renewal contract specifies the method to be used to determine rent adjustments. Adjustments must not result in material differences between rents charged for assisted units and comparable unassisted units except as those differences existed at contract execution. Special adjustments to contract rents, within the original contract term, may also be made to the extent deemed necessary by the PHA or HUD (24 CFR sections 880.609, 881.601, 882.410, 882.808(e), 883.701, 884.109, 886.112, 886.312(c) and Section 524 of Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA) Title V of the HUD Fiscal Year 1998 Appropriations Act, Pub. L. 105-65, as amended). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure rent changes were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 12 exceptions: - 12 files where the rent on the 50059 did not match the approved rent schedules Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over rent changes. Effect: The Commission is not in compliance with program requirements over rent changes. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 007 – PBRA/MOD – Utility Allowances Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner must (a) establish or ensure tenant utility allowances based on utility consumption and rate data for various sized units, structure types, and fuel types, (b) make an annual review of tenant utility allowances to determine their reasonableness, and (c) adjust the allowances, when appropriate (24 CFR sections 5.603, 880.610, 881.601, 882.510, 882.808(k), 883.701, 884.220, 886.126, and 886.326). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure utility allowances were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 6 exceptions: 6 files where the utility allowance on the 50058/50059 did not match the approved utility allowance Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over utility allowances. Effect: The Commission is not in compliance with program requirements over utility allowances. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 008 – PBRA/MOD – Vacant Units Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: The PHA or owner must reduce claims for assistance on vacant units under certain circumstances. However, there are instances where special claims are allowed for vacancy losses, unpaid rent, and tenant damages on eligible units (24 CFR sections 880.611, 881.601, 882.411, 882.808(f), 883.701, 884.106, 886.109, and 886.309). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure claims for assistance were terminated. Questioned costs: $15,963 Context: Testing of 11 tenant files revealed the following 2 exceptions: - 2 files where claims for assistance were not properly terminated Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over vacant units. Effect: The Commission is not in compliance with program requirements over vacant units. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 003 – PBRA/MOD Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23-6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: $21,838 Context: Testing of 60 tenant files for eligibility revealed that 38 files had the following exceptions: -26 files were missing the application which includes signoff from the program specialist -28 files were missing documentation needed to support and recalculate total income per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the asset total per HUD-50058/HUD-50059 -27 files that were missing support needed to substantiate the expenses total per HUD-50058/HUD-50059 -3 files where the annual examination was not processed within 12-month regulatory period -34 files that were missing the recertification checklist as part of their internal controls Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 004 – PBRA/MOD Housing Quality Standards Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that inspection requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 60 PBRA tenant files for annual inspection standards revealed the following exceptions: -40 instances where tenant files were missing one or more inspections and when inspections were included, it was indeterminable whether they were within the regulatory period -26 files missing the letters sent to tenants informing them of the scheduled HQS inspections Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 005 – PBRA/MOD - Public Housing Information Center (PIC) & Tenant Rental Assistance Certification (TRACS) Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 4 files had the following exceptions: -2 files failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC -2 instances where the Authority failed to provide the TRACS submission Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Yes Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 006 – PBRA/MOD – Contract Rent Change Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner applies or ensures annual adjustments to contract rents are applied. The HAP original term contract or renewal contract specifies the method to be used to determine rent adjustments. Adjustments must not result in material differences between rents charged for assisted units and comparable unassisted units except as those differences existed at contract execution. Special adjustments to contract rents, within the original contract term, may also be made to the extent deemed necessary by the PHA or HUD (24 CFR sections 880.609, 881.601, 882.410, 882.808(e), 883.701, 884.109, 886.112, 886.312(c) and Section 524 of Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA) Title V of the HUD Fiscal Year 1998 Appropriations Act, Pub. L. 105-65, as amended). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure rent changes were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 12 exceptions: - 12 files where the rent on the 50059 did not match the approved rent schedules Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over rent changes. Effect: The Commission is not in compliance with program requirements over rent changes. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that rent changes are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 007 – PBRA/MOD – Utility Allowances Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Material Weakness in Internal Control over Compliance. -Material Noncompliance (Modified Opinion) Criteria: The PHA or owner must (a) establish or ensure tenant utility allowances based on utility consumption and rate data for various sized units, structure types, and fuel types, (b) make an annual review of tenant utility allowances to determine their reasonableness, and (c) adjust the allowances, when appropriate (24 CFR sections 5.603, 880.610, 881.601, 882.510, 882.808(k), 883.701, 884.220, 886.126, and 886.326). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure utility allowances were properly applied. Questioned costs: Unknown Context: Testing of 40 tenant files revealed the following 6 exceptions: 6 files where the utility allowance on the 50058/50059 did not match the approved utility allowance Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over utility allowances. Effect: The Commission is not in compliance with program requirements over utility allowances. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that utility allowances are properly applied. View of Responsible Officials: There is no disagreement with the audit finding.

2024 – 008 – PBRA/MOD – Vacant Units Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/23 - 6/30/24) Award Period: July 1, 2023 through June 30, 2024 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria: The PHA or owner must reduce claims for assistance on vacant units under certain circumstances. However, there are instances where special claims are allowed for vacancy losses, unpaid rent, and tenant damages on eligible units (24 CFR sections 880.611, 881.601, 882.411, 882.808(f), 883.701, 884.106, 886.109, and 886.309). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure claims for assistance were terminated. Questioned costs: $15,963 Context: Testing of 11 tenant files revealed the following 2 exceptions: - 2 files where claims for assistance were not properly terminated Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over vacant units. Effect: The Commission is not in compliance with program requirements over vacant units. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. View of Responsible Officials: There is no disagreement with the audit finding.