FINDING 2023-005
FEDERAL PROGRAMS COMMUNITY DEVELOPMENT BLOCK GRANTS/ ENTITLEMENT GRANTS CLUSTER:
COMMUNITY DEVELOPMENT BLOCK GRANTS/ ENTITLEMENT GRANTS
(ASSISTANCE LISTING NUMBER 14.218)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING COMPLIANCE AND INTERNAL CONTROL
COMPLIANCE
REQUIREMENT PROGRAM INCOME
CONDITION During the Program Income test, I noted that the Municipality did not spend down program income funds on hand before grant funds. The Program had $224,800 in program income funds available to be disbursed for eligible activities during fiscal year 2022-2023. Nevertheless, the program only spends $92,126 of these funds and made cash withdrawals of CDBG funds for activities that could be covered with program income funds.
CRITERIA Code of Federal Regulations 24, Section 570.504(b)(2)(ii) states that if the recipient chooses to retain program income, that program income shall be disbursed for eligible activities before additional cash withdrawals are made from the U. S. Treasury.
CAUSE During the fiscal year 2022-2023, the Program did not maintain appropriate internal controls to ensure that all program income funds are used before additional grant funds drawdowns are made.
EFFECT When Grant Funds are used for an expenditure in place of the Program Income on hand, the grantee will not have the opportunity to increase the amounts available for program activities.
RECOMMENDATION I recommend management continue improving the internal controls and procedures to ensure that the program income funds are used for CDBG activities before withdrawal of CDBG funds.
QUESTIONED COSTS None
PRIOR YEAR FINDING A similar finding was presented in prior year Schedule of Findings and Questioned Costs (2022-005)
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to ensure that the program income funds will be used for CDBG activities before the withdrawal of CDBG funds.
FINDING NUMBER 2023-006
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS
(ASSISTANCE LISTING NUMBER 14.871)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIREMENT ELIGIBILITY
CONDITION During the Eligibility test, twenty (25) participants’ files were examined related to the reexamination process, and noted the following conditions:
a. In seven (7) participants’ files, the Enterprise Income Verification (EIV) report corresponding to the annual reexamination selected for evaluation, was not available for my review.
b. In three (3) participants’ files, the housing assistance payment was incorrect due to errors in the determination of the family income (2 files) or applicable deductions (1 file) used in the calculation.
c. Four (4) participants’ files did not include the certificate of criminal record and one (1) participant file did not include the certification of the verification in the sex offenders register for one or more adult family members.
CRITERIA Code of Federal Regulation 24, Section 982.516 (a) (1) states that the PHA must conduct a reexamination of family income and composition at least annually; (2) the PHA must obtain and document in the tenant file third party verification of the following factors or must document in the file why third party verification was not available: (A) reported family annual income; (B) the value of assets; (C) expenses related to deductions from annual income; and (D) other factors that affects the determination of adjusted income.
In accordance with the regulations at 24 CFR 5.856 and 5.905, O/As and PHAs must perform necessary criminal history background checks to determine if an applicant, or a member of an applicant’s household, is subject to a lifetime registration requirement under a state sex offender registration program. This check must be carried out with respects to the State in which the housing is located and with respect to States where the applicant and members of the applicant’s household are known to have resided.
CAUSE The Program’s internal controls and procedures failed to ensure that the reexamination and HAP determination processes were performed according to program requirements and guidelines. Also, the internal controls did not ensure that all the required documentation necessary for the reexamination process was obtained from the participants.
EFFECT The lack of monitoring and adequate supporting documentation during the reexamination processes could lead to the approval and disbursement of improper amounts and the approval of benefits to people that do not qualify.
RECOMMENDATION I recommend management to continue strengthening its internal controls and procedures to ensure that the re-examination and HAP determination processes are performed according to program requirements and guidelines. Also, management must reinforce the internal controls to ensure that all the required documentation necessary for the reexamination process is obtained in a timely manner.
QUESTIONED COSTS None
PRIOR YEAR FINDING A similar finding was presented in prior year Schedule of Findings and Questioned Costs (2022-006)
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure that the re-examination and HAP determination processes will be performed according to program requirements and guidelines, and to obtain in a timely manner all the required documentation for each reexamination executed.
FINDING NUMBER 2023-007
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS/ EMERGENCY HOUSING VOUCHERS
(ASSISTANCE LISTING NUMBERS 14.871/ 14.EHV)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIIREMENT REPORTING
CONDITION The Program did not comply with the financial and special reporting requirements, as follows:
1. The GAAP-based audited financial information of the programs for the fiscal year ended June 30, 2023, was not submitted on time through the FASS-PH system.
2. The expenditures reported in the Voucher Management System (VMS) for the fiscal year ended June 30, 2023, have differences with the amounts reported in the draft audited financial information for the fiscal year ended June 30, 2023, submitted through the FASS-PH system, as follows:
HOUSING CHOICE VOUCHERS VMS FASS-PH DIFFERENCE
Operating and Administrative $ 87,751 $ 114,508 $ (26,757)
Housing Assistance Payments 527,986 540,385 (12,399)
HAP Portability-in 224,441 226,604 (2,163)
Total $ 840,178 $ 881,497 $ (41,319)
EMERGENCY HOUSING VOUCHERS VMS FASS-PH DIFFERENCE
Operating and Administrative $ 6,435 $ 8,183 $ (1,748)
Total Operating -Tenants 500 500 -
Emergency Housing Vouchers 41,191 46,407 (5,216)
Total $ 48,126 $ 55,090 $ (6,964)
CRITERIA 24 CFR, Section 982.158 (a) (b) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record-keeping. Also, the PHA must furnish HUD accounts and other records, reports, documents, and information, as required by HUD.
Also, 24 CFR, Section 5.801 (b), submission of financial information. Entities to which this subpart is applicable must provide to HUD such financial information as required by HUD. Such information must be provided on an annual basis, except as required more frequently under paragraph (c) (4) of this section. This information must be: (1) prepared in accordance with Generally Accepted Accounting Principles; (2) submitted electronically to HUD through the internet, or in such other electronic format designated by HUD, or in such non-electronic format as HUD may allow if the burden or cost of electronic reporting is determined by HUD to be excessive.
In addition, Section 5.801 (d), reporting compliance dates. Unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F.
CAUSE The internal controls and procedures maintained by the Municipality failed to ensure the accuracy of the expenditures reported in the VMS and the timely submission to HUD of the GAAP based audited financial information.
EFFECT The lack of proper filing of required financial reports may lead HUD to impose special conditions regarding the use of funds to the Municipality. Also, HUD relies on key line items of the reports to determine the reasonableness of the data submitted for the purposes of calculating funding under the program. Accordingly, future funding for the Municipality may be affected negatively.
RECOMMENDATION The Municipality should continue strengthening the established internal controls and procedures to submit to HUD the financial reports according to applicable requirements.
QUESTIONED COSTS None
PRIOR YEAR FINDING A similar finding was presented in prior year Schedule of Findings and Questioned Costs (2022-007).
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure the submission of financial information according to applicable requirements, and to reconcile the amounts reported in the Voucher Management System (VMS) with the accounting records and proceed with any necessary corrections about the information previously reported. Moreover, the audited financial data schedule for the fiscal year 2022-2023 will be submitted as soon as the Single Audit Report be finally issued by the external auditors.
FINDING NUMBER 2023-008
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS/ EMERGENCY HOUSING VOUCHERS
(ASSISTANCE LISTING NUMBERS 14.871/ 14.EHV)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIREMENT SPECIAL TEST- ROLLING FORWARD EQUITY BALANCES
CONDITION During the examination of the program accounting records, I noted that the equity balances reported in the Voucher Management System (VMS) for the month of June 30, 2023, have differences with the amounts reported in the draft audited financial information for the fiscal year ended June 30, 2023, submitted through the FASS-PH system, as follows:
VMS FASS-PH DIFFERENCE
HCV - Restricted Net Position Funds (RNP) $ 34,760 $ 52,596 $ (17,836)
HCV -Unrestricted Net Position Funds (UNP) $ 66,142 $ 42,043 $ 24,099
Emergency Housing Vouchers - Restricted Net Position Funds (RNP) $ 575 $ 19,471 $ (18,896)
Emergency Housing Vouchers - Unrestricted Net Position Funds (UNP) $ (3,391) $ 6,693 $ (10,084)
CRITERIA Code of Federal Regulations, 24 CFR, Section 982.158 (a) (b) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record-keeping. Also, the PHA must furnish HUD accounts and other records, reports, documents, and information, as required by HUD.
CAUSE The Program’s internal controls and procedures over the accounting records failed to assure that the equity balances were properly calculated and reported in the VMS.
EFFECT The Program is not reporting the correct balances of restricted net position and unrestricted net position to HUD.
RECOMMENDATION I recommend management to prepare an analysis of the equity balances and adjust or correct any errors reported in the VMS.
QUESTIONED COSTS None
PRIOR YEAR FINDING This finding was presented in prior year Schedule of Findings and Questioned Costs (2022-009).
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure the equity balances were properly calculated and reported in the Voucher Management System (VMS). Also, the Program staff were instructed to analyze previous equity balances reported in the VMS and realize any necessary corrections.
FINDING NUMBER 2023-007
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS/ EMERGENCY HOUSING VOUCHERS
(ASSISTANCE LISTING NUMBERS 14.871/ 14.EHV)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIIREMENT REPORTING
CONDITION The Program did not comply with the financial and special reporting requirements, as follows:
1. The GAAP-based audited financial information of the programs for the fiscal year ended June 30, 2023, was not submitted on time through the FASS-PH system.
2. The expenditures reported in the Voucher Management System (VMS) for the fiscal year ended June 30, 2023, have differences with the amounts reported in the draft audited financial information for the fiscal year ended June 30, 2023, submitted through the FASS-PH system, as follows:
HOUSING CHOICE VOUCHERS VMS FASS-PH DIFFERENCE
Operating and Administrative $ 87,751 $ 114,508 $ (26,757)
Housing Assistance Payments 527,986 540,385 (12,399)
HAP Portability-in 224,441 226,604 (2,163)
Total $ 840,178 $ 881,497 $ (41,319)
EMERGENCY HOUSING VOUCHERS VMS FASS-PH DIFFERENCE
Operating and Administrative $ 6,435 $ 8,183 $ (1,748)
Total Operating -Tenants 500 500 -
Emergency Housing Vouchers 41,191 46,407 (5,216)
Total $ 48,126 $ 55,090 $ (6,964)
CRITERIA 24 CFR, Section 982.158 (a) (b) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record-keeping. Also, the PHA must furnish HUD accounts and other records, reports, documents, and information, as required by HUD.
Also, 24 CFR, Section 5.801 (b), submission of financial information. Entities to which this subpart is applicable must provide to HUD such financial information as required by HUD. Such information must be provided on an annual basis, except as required more frequently under paragraph (c) (4) of this section. This information must be: (1) prepared in accordance with Generally Accepted Accounting Principles; (2) submitted electronically to HUD through the internet, or in such other electronic format designated by HUD, or in such non-electronic format as HUD may allow if the burden or cost of electronic reporting is determined by HUD to be excessive.
In addition, Section 5.801 (d), reporting compliance dates. Unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F.
CAUSE The internal controls and procedures maintained by the Municipality failed to ensure the accuracy of the expenditures reported in the VMS and the timely submission to HUD of the GAAP based audited financial information.
EFFECT The lack of proper filing of required financial reports may lead HUD to impose special conditions regarding the use of funds to the Municipality. Also, HUD relies on key line items of the reports to determine the reasonableness of the data submitted for the purposes of calculating funding under the program. Accordingly, future funding for the Municipality may be affected negatively.
RECOMMENDATION The Municipality should continue strengthening the established internal controls and procedures to submit to HUD the financial reports according to applicable requirements.
QUESTIONED COSTS None
PRIOR YEAR FINDING A similar finding was presented in prior year Schedule of Findings and Questioned Costs (2022-007).
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure the submission of financial information according to applicable requirements, and to reconcile the amounts reported in the Voucher Management System (VMS) with the accounting records and proceed with any necessary corrections about the information previously reported. Moreover, the audited financial data schedule for the fiscal year 2022-2023 will be submitted as soon as the Single Audit Report be finally issued by the external auditors.
FINDING NUMBER 2023-008
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS/ EMERGENCY HOUSING VOUCHERS
(ASSISTANCE LISTING NUMBERS 14.871/ 14.EHV)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIREMENT SPECIAL TEST- ROLLING FORWARD EQUITY BALANCES
CONDITION During the examination of the program accounting records, I noted that the equity balances reported in the Voucher Management System (VMS) for the month of June 30, 2023, have differences with the amounts reported in the draft audited financial information for the fiscal year ended June 30, 2023, submitted through the FASS-PH system, as follows:
VMS FASS-PH DIFFERENCE
HCV - Restricted Net Position Funds (RNP) $ 34,760 $ 52,596 $ (17,836)
HCV -Unrestricted Net Position Funds (UNP) $ 66,142 $ 42,043 $ 24,099
Emergency Housing Vouchers - Restricted Net Position Funds (RNP) $ 575 $ 19,471 $ (18,896)
Emergency Housing Vouchers - Unrestricted Net Position Funds (UNP) $ (3,391) $ 6,693 $ (10,084)
CRITERIA Code of Federal Regulations, 24 CFR, Section 982.158 (a) (b) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record-keeping. Also, the PHA must furnish HUD accounts and other records, reports, documents, and information, as required by HUD.
CAUSE The Program’s internal controls and procedures over the accounting records failed to assure that the equity balances were properly calculated and reported in the VMS.
EFFECT The Program is not reporting the correct balances of restricted net position and unrestricted net position to HUD.
RECOMMENDATION I recommend management to prepare an analysis of the equity balances and adjust or correct any errors reported in the VMS.
QUESTIONED COSTS None
PRIOR YEAR FINDING This finding was presented in prior year Schedule of Findings and Questioned Costs (2022-009).
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure the equity balances were properly calculated and reported in the Voucher Management System (VMS). Also, the Program staff were instructed to analyze previous equity balances reported in the VMS and realize any necessary corrections.
FINDING 2023-005
FEDERAL PROGRAMS COMMUNITY DEVELOPMENT BLOCK GRANTS/ ENTITLEMENT GRANTS CLUSTER:
COMMUNITY DEVELOPMENT BLOCK GRANTS/ ENTITLEMENT GRANTS
(ASSISTANCE LISTING NUMBER 14.218)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING COMPLIANCE AND INTERNAL CONTROL
COMPLIANCE
REQUIREMENT PROGRAM INCOME
CONDITION During the Program Income test, I noted that the Municipality did not spend down program income funds on hand before grant funds. The Program had $224,800 in program income funds available to be disbursed for eligible activities during fiscal year 2022-2023. Nevertheless, the program only spends $92,126 of these funds and made cash withdrawals of CDBG funds for activities that could be covered with program income funds.
CRITERIA Code of Federal Regulations 24, Section 570.504(b)(2)(ii) states that if the recipient chooses to retain program income, that program income shall be disbursed for eligible activities before additional cash withdrawals are made from the U. S. Treasury.
CAUSE During the fiscal year 2022-2023, the Program did not maintain appropriate internal controls to ensure that all program income funds are used before additional grant funds drawdowns are made.
EFFECT When Grant Funds are used for an expenditure in place of the Program Income on hand, the grantee will not have the opportunity to increase the amounts available for program activities.
RECOMMENDATION I recommend management continue improving the internal controls and procedures to ensure that the program income funds are used for CDBG activities before withdrawal of CDBG funds.
QUESTIONED COSTS None
PRIOR YEAR FINDING A similar finding was presented in prior year Schedule of Findings and Questioned Costs (2022-005)
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to ensure that the program income funds will be used for CDBG activities before the withdrawal of CDBG funds.
FINDING NUMBER 2023-006
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS
(ASSISTANCE LISTING NUMBER 14.871)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIREMENT ELIGIBILITY
CONDITION During the Eligibility test, twenty (25) participants’ files were examined related to the reexamination process, and noted the following conditions:
a. In seven (7) participants’ files, the Enterprise Income Verification (EIV) report corresponding to the annual reexamination selected for evaluation, was not available for my review.
b. In three (3) participants’ files, the housing assistance payment was incorrect due to errors in the determination of the family income (2 files) or applicable deductions (1 file) used in the calculation.
c. Four (4) participants’ files did not include the certificate of criminal record and one (1) participant file did not include the certification of the verification in the sex offenders register for one or more adult family members.
CRITERIA Code of Federal Regulation 24, Section 982.516 (a) (1) states that the PHA must conduct a reexamination of family income and composition at least annually; (2) the PHA must obtain and document in the tenant file third party verification of the following factors or must document in the file why third party verification was not available: (A) reported family annual income; (B) the value of assets; (C) expenses related to deductions from annual income; and (D) other factors that affects the determination of adjusted income.
In accordance with the regulations at 24 CFR 5.856 and 5.905, O/As and PHAs must perform necessary criminal history background checks to determine if an applicant, or a member of an applicant’s household, is subject to a lifetime registration requirement under a state sex offender registration program. This check must be carried out with respects to the State in which the housing is located and with respect to States where the applicant and members of the applicant’s household are known to have resided.
CAUSE The Program’s internal controls and procedures failed to ensure that the reexamination and HAP determination processes were performed according to program requirements and guidelines. Also, the internal controls did not ensure that all the required documentation necessary for the reexamination process was obtained from the participants.
EFFECT The lack of monitoring and adequate supporting documentation during the reexamination processes could lead to the approval and disbursement of improper amounts and the approval of benefits to people that do not qualify.
RECOMMENDATION I recommend management to continue strengthening its internal controls and procedures to ensure that the re-examination and HAP determination processes are performed according to program requirements and guidelines. Also, management must reinforce the internal controls to ensure that all the required documentation necessary for the reexamination process is obtained in a timely manner.
QUESTIONED COSTS None
PRIOR YEAR FINDING A similar finding was presented in prior year Schedule of Findings and Questioned Costs (2022-006)
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure that the re-examination and HAP determination processes will be performed according to program requirements and guidelines, and to obtain in a timely manner all the required documentation for each reexamination executed.
FINDING NUMBER 2023-007
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS/ EMERGENCY HOUSING VOUCHERS
(ASSISTANCE LISTING NUMBERS 14.871/ 14.EHV)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIIREMENT REPORTING
CONDITION The Program did not comply with the financial and special reporting requirements, as follows:
1. The GAAP-based audited financial information of the programs for the fiscal year ended June 30, 2023, was not submitted on time through the FASS-PH system.
2. The expenditures reported in the Voucher Management System (VMS) for the fiscal year ended June 30, 2023, have differences with the amounts reported in the draft audited financial information for the fiscal year ended June 30, 2023, submitted through the FASS-PH system, as follows:
HOUSING CHOICE VOUCHERS VMS FASS-PH DIFFERENCE
Operating and Administrative $ 87,751 $ 114,508 $ (26,757)
Housing Assistance Payments 527,986 540,385 (12,399)
HAP Portability-in 224,441 226,604 (2,163)
Total $ 840,178 $ 881,497 $ (41,319)
EMERGENCY HOUSING VOUCHERS VMS FASS-PH DIFFERENCE
Operating and Administrative $ 6,435 $ 8,183 $ (1,748)
Total Operating -Tenants 500 500 -
Emergency Housing Vouchers 41,191 46,407 (5,216)
Total $ 48,126 $ 55,090 $ (6,964)
CRITERIA 24 CFR, Section 982.158 (a) (b) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record-keeping. Also, the PHA must furnish HUD accounts and other records, reports, documents, and information, as required by HUD.
Also, 24 CFR, Section 5.801 (b), submission of financial information. Entities to which this subpart is applicable must provide to HUD such financial information as required by HUD. Such information must be provided on an annual basis, except as required more frequently under paragraph (c) (4) of this section. This information must be: (1) prepared in accordance with Generally Accepted Accounting Principles; (2) submitted electronically to HUD through the internet, or in such other electronic format designated by HUD, or in such non-electronic format as HUD may allow if the burden or cost of electronic reporting is determined by HUD to be excessive.
In addition, Section 5.801 (d), reporting compliance dates. Unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F.
CAUSE The internal controls and procedures maintained by the Municipality failed to ensure the accuracy of the expenditures reported in the VMS and the timely submission to HUD of the GAAP based audited financial information.
EFFECT The lack of proper filing of required financial reports may lead HUD to impose special conditions regarding the use of funds to the Municipality. Also, HUD relies on key line items of the reports to determine the reasonableness of the data submitted for the purposes of calculating funding under the program. Accordingly, future funding for the Municipality may be affected negatively.
RECOMMENDATION The Municipality should continue strengthening the established internal controls and procedures to submit to HUD the financial reports according to applicable requirements.
QUESTIONED COSTS None
PRIOR YEAR FINDING A similar finding was presented in prior year Schedule of Findings and Questioned Costs (2022-007).
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure the submission of financial information according to applicable requirements, and to reconcile the amounts reported in the Voucher Management System (VMS) with the accounting records and proceed with any necessary corrections about the information previously reported. Moreover, the audited financial data schedule for the fiscal year 2022-2023 will be submitted as soon as the Single Audit Report be finally issued by the external auditors.
FINDING NUMBER 2023-008
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS/ EMERGENCY HOUSING VOUCHERS
(ASSISTANCE LISTING NUMBERS 14.871/ 14.EHV)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIREMENT SPECIAL TEST- ROLLING FORWARD EQUITY BALANCES
CONDITION During the examination of the program accounting records, I noted that the equity balances reported in the Voucher Management System (VMS) for the month of June 30, 2023, have differences with the amounts reported in the draft audited financial information for the fiscal year ended June 30, 2023, submitted through the FASS-PH system, as follows:
VMS FASS-PH DIFFERENCE
HCV - Restricted Net Position Funds (RNP) $ 34,760 $ 52,596 $ (17,836)
HCV -Unrestricted Net Position Funds (UNP) $ 66,142 $ 42,043 $ 24,099
Emergency Housing Vouchers - Restricted Net Position Funds (RNP) $ 575 $ 19,471 $ (18,896)
Emergency Housing Vouchers - Unrestricted Net Position Funds (UNP) $ (3,391) $ 6,693 $ (10,084)
CRITERIA Code of Federal Regulations, 24 CFR, Section 982.158 (a) (b) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record-keeping. Also, the PHA must furnish HUD accounts and other records, reports, documents, and information, as required by HUD.
CAUSE The Program’s internal controls and procedures over the accounting records failed to assure that the equity balances were properly calculated and reported in the VMS.
EFFECT The Program is not reporting the correct balances of restricted net position and unrestricted net position to HUD.
RECOMMENDATION I recommend management to prepare an analysis of the equity balances and adjust or correct any errors reported in the VMS.
QUESTIONED COSTS None
PRIOR YEAR FINDING This finding was presented in prior year Schedule of Findings and Questioned Costs (2022-009).
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure the equity balances were properly calculated and reported in the Voucher Management System (VMS). Also, the Program staff were instructed to analyze previous equity balances reported in the VMS and realize any necessary corrections.
FINDING NUMBER 2023-007
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS/ EMERGENCY HOUSING VOUCHERS
(ASSISTANCE LISTING NUMBERS 14.871/ 14.EHV)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIIREMENT REPORTING
CONDITION The Program did not comply with the financial and special reporting requirements, as follows:
1. The GAAP-based audited financial information of the programs for the fiscal year ended June 30, 2023, was not submitted on time through the FASS-PH system.
2. The expenditures reported in the Voucher Management System (VMS) for the fiscal year ended June 30, 2023, have differences with the amounts reported in the draft audited financial information for the fiscal year ended June 30, 2023, submitted through the FASS-PH system, as follows:
HOUSING CHOICE VOUCHERS VMS FASS-PH DIFFERENCE
Operating and Administrative $ 87,751 $ 114,508 $ (26,757)
Housing Assistance Payments 527,986 540,385 (12,399)
HAP Portability-in 224,441 226,604 (2,163)
Total $ 840,178 $ 881,497 $ (41,319)
EMERGENCY HOUSING VOUCHERS VMS FASS-PH DIFFERENCE
Operating and Administrative $ 6,435 $ 8,183 $ (1,748)
Total Operating -Tenants 500 500 -
Emergency Housing Vouchers 41,191 46,407 (5,216)
Total $ 48,126 $ 55,090 $ (6,964)
CRITERIA 24 CFR, Section 982.158 (a) (b) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record-keeping. Also, the PHA must furnish HUD accounts and other records, reports, documents, and information, as required by HUD.
Also, 24 CFR, Section 5.801 (b), submission of financial information. Entities to which this subpart is applicable must provide to HUD such financial information as required by HUD. Such information must be provided on an annual basis, except as required more frequently under paragraph (c) (4) of this section. This information must be: (1) prepared in accordance with Generally Accepted Accounting Principles; (2) submitted electronically to HUD through the internet, or in such other electronic format designated by HUD, or in such non-electronic format as HUD may allow if the burden or cost of electronic reporting is determined by HUD to be excessive.
In addition, Section 5.801 (d), reporting compliance dates. Unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F.
CAUSE The internal controls and procedures maintained by the Municipality failed to ensure the accuracy of the expenditures reported in the VMS and the timely submission to HUD of the GAAP based audited financial information.
EFFECT The lack of proper filing of required financial reports may lead HUD to impose special conditions regarding the use of funds to the Municipality. Also, HUD relies on key line items of the reports to determine the reasonableness of the data submitted for the purposes of calculating funding under the program. Accordingly, future funding for the Municipality may be affected negatively.
RECOMMENDATION The Municipality should continue strengthening the established internal controls and procedures to submit to HUD the financial reports according to applicable requirements.
QUESTIONED COSTS None
PRIOR YEAR FINDING A similar finding was presented in prior year Schedule of Findings and Questioned Costs (2022-007).
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure the submission of financial information according to applicable requirements, and to reconcile the amounts reported in the Voucher Management System (VMS) with the accounting records and proceed with any necessary corrections about the information previously reported. Moreover, the audited financial data schedule for the fiscal year 2022-2023 will be submitted as soon as the Single Audit Report be finally issued by the external auditors.
FINDING NUMBER 2023-008
FEDERAL PROGRAM HOUSING VOUCHER CLUSTER:
SECTION 8 HOUSING CHOICE VOUCHERS/ EMERGENCY HOUSING VOUCHERS
(ASSISTANCE LISTING NUMBERS 14.871/ 14.EHV)
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
TYPE OF FINDING MATERIAL WEAKNESS AND INSTANCE OF NONCOMPLIANCE
COMPLIANCE
REQUIREMENT SPECIAL TEST- ROLLING FORWARD EQUITY BALANCES
CONDITION During the examination of the program accounting records, I noted that the equity balances reported in the Voucher Management System (VMS) for the month of June 30, 2023, have differences with the amounts reported in the draft audited financial information for the fiscal year ended June 30, 2023, submitted through the FASS-PH system, as follows:
VMS FASS-PH DIFFERENCE
HCV - Restricted Net Position Funds (RNP) $ 34,760 $ 52,596 $ (17,836)
HCV -Unrestricted Net Position Funds (UNP) $ 66,142 $ 42,043 $ 24,099
Emergency Housing Vouchers - Restricted Net Position Funds (RNP) $ 575 $ 19,471 $ (18,896)
Emergency Housing Vouchers - Unrestricted Net Position Funds (UNP) $ (3,391) $ 6,693 $ (10,084)
CRITERIA Code of Federal Regulations, 24 CFR, Section 982.158 (a) (b) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record-keeping. Also, the PHA must furnish HUD accounts and other records, reports, documents, and information, as required by HUD.
CAUSE The Program’s internal controls and procedures over the accounting records failed to assure that the equity balances were properly calculated and reported in the VMS.
EFFECT The Program is not reporting the correct balances of restricted net position and unrestricted net position to HUD.
RECOMMENDATION I recommend management to prepare an analysis of the equity balances and adjust or correct any errors reported in the VMS.
QUESTIONED COSTS None
PRIOR YEAR FINDING This finding was presented in prior year Schedule of Findings and Questioned Costs (2022-009).
VIEWS OF RESPONSIBLE
OFFICIALS AND PLANNED
CORRECTIVE ACTION Instructions were given to the Program staff to strengthen existing internal controls and procedures to ensure the equity balances were properly calculated and reported in the Voucher Management System (VMS). Also, the Program staff were instructed to analyze previous equity balances reported in the VMS and realize any necessary corrections.