2024-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal Awards: (a) Be necessary and reasonable for the performance of the Federal Award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403)
CONDITION
As disclosed in Finding 2024-001, we identified three (3) instances where invoices were missing proper approvals.
CAUSE
As disclosed in Finding 2024-001, the Authority did not establish an effective control environment or effective control activities over compliance.
EFFECT
The Authority is not in compliance with its Fiscal Policies and Procedures and its Federal Award program requirements.
QUESTIONED COSTS
None identified.
CONTEXT
We reviewed the Authority’s internal controls over compliance with federal awards.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
2024-004 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
The unaudited FDS was required to be submitted to HUD by September 15, 2024.
CONDITION
The Authority’s unaudited FDS was submitted to HUD on September 16, 2024.
CAUSE
The Authority’s internal control processes were not sufficient to ensure timely filing of the unaudited FDS.
EFFECT
As a result of not submitting the FDS timely, HUD was limited in its ability to conduct proper monitoring and oversight of federal programs.
QUESTIONED COSTS
None identified.
CONTEXT
The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure its year-end closing process is sufficient to allow or
the timely filing of the unaudited FDS.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal Awards: (a) Be necessary and reasonable for the performance of the Federal Award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403)
CONDITION
As disclosed in Finding 2024-001, we identified three (3) instances where invoices were missing proper approvals.
CAUSE
As disclosed in Finding 2024-001, the Authority did not establish an effective control environment or effective control activities over compliance.
EFFECT
The Authority is not in compliance with its Fiscal Policies and Procedures and its Federal Award program requirements.
QUESTIONED COSTS
None identified.
CONTEXT
We reviewed the Authority’s internal controls over compliance with federal awards.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
2024-004 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
The unaudited FDS was required to be submitted to HUD by September 15, 2024.
CONDITION
The Authority’s unaudited FDS was submitted to HUD on September 16, 2024.
CAUSE
The Authority’s internal control processes were not sufficient to ensure timely filing of the unaudited FDS.
EFFECT
As a result of not submitting the FDS timely, HUD was limited in its ability to conduct proper monitoring and oversight of federal programs.
QUESTIONED COSTS
None identified.
CONTEXT
The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure its year-end closing process is sufficient to allow or
the timely filing of the unaudited FDS.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal Awards: (a) Be necessary and reasonable for the performance of the Federal Award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403)
CONDITION
As disclosed in Finding 2024-001, we identified three (3) instances where invoices were missing proper approvals.
CAUSE
As disclosed in Finding 2024-001, the Authority did not establish an effective control environment or effective control activities over compliance.
EFFECT
The Authority is not in compliance with its Fiscal Policies and Procedures and its Federal Award program requirements.
QUESTIONED COSTS
None identified.
CONTEXT
We reviewed the Authority’s internal controls over compliance with federal awards.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
2024-004 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
The unaudited FDS was required to be submitted to HUD by September 15, 2024.
CONDITION
The Authority’s unaudited FDS was submitted to HUD on September 16, 2024.
CAUSE
The Authority’s internal control processes were not sufficient to ensure timely filing of the unaudited FDS.
EFFECT
As a result of not submitting the FDS timely, HUD was limited in its ability to conduct proper monitoring and oversight of federal programs.
QUESTIONED COSTS
None identified.
CONTEXT
The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure its year-end closing process is sufficient to allow or
the timely filing of the unaudited FDS.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal Awards: (a) Be necessary and reasonable for the performance of the Federal Award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403)
CONDITION
As disclosed in Finding 2024-001, we identified three (3) instances where invoices were missing proper approvals.
CAUSE
As disclosed in Finding 2024-001, the Authority did not establish an effective control environment or effective control activities over compliance.
EFFECT
The Authority is not in compliance with its Fiscal Policies and Procedures and its Federal Award program requirements.
QUESTIONED COSTS
None identified.
CONTEXT
We reviewed the Authority’s internal controls over compliance with federal awards.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
2024-003 – PERIOD OF PERFORMANCE
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
1. Obligations - Unless an extension is approved by HUD, a PHA must obligate at least 90 percent of each Capital Fund grant, including formula grants, non-accumulating RHF, natural disaster, and lead-based paint grants within 24 months of the funds becoming available to the PHA for obligation. For emergency grants, safety and security grants and safety and security-carbon monoxide grants, the PHA must obligate at least 90 percent within twelve months of the funds becoming available. The funds become available when HUD executes the Annual Contributions Contract (ACC) Amendment (24 CFR section 905.306).
2. Expenditures - For Capital Fund formula, RHF, natural disaster, and lead-based paint grants, unless HUD approves an extension, a PHA must expend all grant funds no later than 48 months after HUD executes the ACC Amendment (24 CFR section 905.306(f)). However, for emergency grants, safety and security grants and safety and security-carbon monoxide grants, a PHA must expend all grant funds no later than 24 months after HUD
executes the ACC Amendment if such a requirement is contained in the ACC Amendment. A PHA must also expend 100% percent of the authorized amount of a Capital Fund grant within 48 months of the date that funds are made available, or the obligation start date. (24 CFR section 905.306).
3. Capital Funds for Operating Costs - Capital Funds transferred to operations (BLI 1406) are not considered obligated until the PHA has budgeted and drawn down the funds. To meet this requirement, the funds must be budgeted in line BLI 1406 (Operations) and the PHA must submit the voucher request in LOCCS. The PHA’s reported obligation amount in LOCCS must be the same amount in the PHA’s accounting system since the date of the voucher request in LOCCS is the point of obligation for funds in BLI 1406. The voucher request date must occur before those funds are reported as obligated in LOCCS under the Obligation & Expenditure tab (24 CFR section 905.314(l)).
CONDITION
The Authority did not fully obligate and expend the Capital Fund Program grants and has not obligated at least 90 percent of the Capital Fund program grants within the 24-month deadline as follows:
2019 Capital Fund Program
2020 Capital Fund Program
2020 Emergency Capital Fund Program
In addition, the Authority did comply with the Capital Funds for Operating Costs requirement for 2019 Capital Fund Program.
CAUSE
The Authority was not aware of approaching obligation and expenditure deadlines and did not take appropriate or sufficient action to mitigate the loss of federal awards.
EFFECT
The Authority did not comply with the Period of Performance requirements.
QUESTIONED COSTS
None identified.
CONTEXT
The 2019 and 2020 CFP grant along with 2020 Emergency CFP grants were not obligated and expended within the applicable allowable period. The 2019 CFP grant funds transferred to operations were obligated before the voucher request was submitted.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority take immediate action to minimize the potential loss of Capital Fund Program grant funds and ensure that controls are in place to prevent deadlines from being missed for future Capital Fund grants. In addition, we recommend the grant fund voucher requests for operating transfers be submitted prior to funds being reported as obligated.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-004 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
The unaudited FDS was required to be submitted to HUD by September 15, 2024.
CONDITION
The Authority’s unaudited FDS was submitted to HUD on September 16, 2024.
CAUSE
The Authority’s internal control processes were not sufficient to ensure timely filing of the unaudited FDS.
EFFECT
As a result of not submitting the FDS timely, HUD was limited in its ability to conduct proper monitoring and oversight of federal programs.
QUESTIONED COSTS
None identified.
CONTEXT
The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure its year-end closing process is sufficient to allow or
the timely filing of the unaudited FDS.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-005 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
HUD-53001, Actual Modernization Cost Certificate (AMCC) Capital Fund Program (OMB No. 2577-0157)
Report authority: 24 CFR 905.324 Data Reporting Requirements For modernization projects, the PHA shall submit the AMCC within 90 days after Expenditure End Date. To initiate the closeout process, the PHA shall submit the AMCC which details actual costs incurred between the DOFA date and the completion of the modernization project.
CONDITION
The Authority did not submit the AMCC for 2019 Capital Fund Program grant within 90 days after Expenditure End Date.
CAUSE
The Authority was not aware of approaching reporting deadlines and did not take appropriate or sufficient action to initiate the closeout process.
EFFECT
The Authority did not comply with the Reporting requirements.
QUESTIONED COSTS
None identified.
CONTEXT
The closeout process for 2019 CFP grant was not initiated within the 90 days after Expenditure
End Date.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure that controls are in place to prevent reporting deadlines from being missed for future Capital Fund grants.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal Awards: (a) Be necessary and reasonable for the performance of the Federal Award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403)
CONDITION
As disclosed in Finding 2024-001, we identified three (3) instances where invoices were missing proper approvals.
CAUSE
As disclosed in Finding 2024-001, the Authority did not establish an effective control environment or effective control activities over compliance.
EFFECT
The Authority is not in compliance with its Fiscal Policies and Procedures and its Federal Award program requirements.
QUESTIONED COSTS
None identified.
CONTEXT
We reviewed the Authority’s internal controls over compliance with federal awards.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
2024-004 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
The unaudited FDS was required to be submitted to HUD by September 15, 2024.
CONDITION
The Authority’s unaudited FDS was submitted to HUD on September 16, 2024.
CAUSE
The Authority’s internal control processes were not sufficient to ensure timely filing of the unaudited FDS.
EFFECT
As a result of not submitting the FDS timely, HUD was limited in its ability to conduct proper monitoring and oversight of federal programs.
QUESTIONED COSTS
None identified.
CONTEXT
The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure its year-end closing process is sufficient to allow or
the timely filing of the unaudited FDS.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal Awards: (a) Be necessary and reasonable for the performance of the Federal Award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403)
CONDITION
As disclosed in Finding 2024-001, we identified three (3) instances where invoices were missing proper approvals.
CAUSE
As disclosed in Finding 2024-001, the Authority did not establish an effective control environment or effective control activities over compliance.
EFFECT
The Authority is not in compliance with its Fiscal Policies and Procedures and its Federal Award program requirements.
QUESTIONED COSTS
None identified.
CONTEXT
We reviewed the Authority’s internal controls over compliance with federal awards.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
2024-004 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
The unaudited FDS was required to be submitted to HUD by September 15, 2024.
CONDITION
The Authority’s unaudited FDS was submitted to HUD on September 16, 2024.
CAUSE
The Authority’s internal control processes were not sufficient to ensure timely filing of the unaudited FDS.
EFFECT
As a result of not submitting the FDS timely, HUD was limited in its ability to conduct proper monitoring and oversight of federal programs.
QUESTIONED COSTS
None identified.
CONTEXT
The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure its year-end closing process is sufficient to allow or
the timely filing of the unaudited FDS.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal Awards: (a) Be necessary and reasonable for the performance of the Federal Award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403)
CONDITION
As disclosed in Finding 2024-001, we identified three (3) instances where invoices were missing proper approvals.
CAUSE
As disclosed in Finding 2024-001, the Authority did not establish an effective control environment or effective control activities over compliance.
EFFECT
The Authority is not in compliance with its Fiscal Policies and Procedures and its Federal Award program requirements.
QUESTIONED COSTS
None identified.
CONTEXT
We reviewed the Authority’s internal controls over compliance with federal awards.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
2024-004 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
The unaudited FDS was required to be submitted to HUD by September 15, 2024.
CONDITION
The Authority’s unaudited FDS was submitted to HUD on September 16, 2024.
CAUSE
The Authority’s internal control processes were not sufficient to ensure timely filing of the unaudited FDS.
EFFECT
As a result of not submitting the FDS timely, HUD was limited in its ability to conduct proper monitoring and oversight of federal programs.
QUESTIONED COSTS
None identified.
CONTEXT
The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure its year-end closing process is sufficient to allow or
the timely filing of the unaudited FDS.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal Awards: (a) Be necessary and reasonable for the performance of the Federal Award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403)
CONDITION
As disclosed in Finding 2024-001, we identified three (3) instances where invoices were missing proper approvals.
CAUSE
As disclosed in Finding 2024-001, the Authority did not establish an effective control environment or effective control activities over compliance.
EFFECT
The Authority is not in compliance with its Fiscal Policies and Procedures and its Federal Award program requirements.
QUESTIONED COSTS
None identified.
CONTEXT
We reviewed the Authority’s internal controls over compliance with federal awards.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
2024-003 – PERIOD OF PERFORMANCE
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
1. Obligations - Unless an extension is approved by HUD, a PHA must obligate at least 90 percent of each Capital Fund grant, including formula grants, non-accumulating RHF, natural disaster, and lead-based paint grants within 24 months of the funds becoming available to the PHA for obligation. For emergency grants, safety and security grants and safety and security-carbon monoxide grants, the PHA must obligate at least 90 percent within twelve months of the funds becoming available. The funds become available when HUD executes the Annual Contributions Contract (ACC) Amendment (24 CFR section 905.306).
2. Expenditures - For Capital Fund formula, RHF, natural disaster, and lead-based paint grants, unless HUD approves an extension, a PHA must expend all grant funds no later than 48 months after HUD executes the ACC Amendment (24 CFR section 905.306(f)). However, for emergency grants, safety and security grants and safety and security-carbon monoxide grants, a PHA must expend all grant funds no later than 24 months after HUD
executes the ACC Amendment if such a requirement is contained in the ACC Amendment. A PHA must also expend 100% percent of the authorized amount of a Capital Fund grant within 48 months of the date that funds are made available, or the obligation start date. (24 CFR section 905.306).
3. Capital Funds for Operating Costs - Capital Funds transferred to operations (BLI 1406) are not considered obligated until the PHA has budgeted and drawn down the funds. To meet this requirement, the funds must be budgeted in line BLI 1406 (Operations) and the PHA must submit the voucher request in LOCCS. The PHA’s reported obligation amount in LOCCS must be the same amount in the PHA’s accounting system since the date of the voucher request in LOCCS is the point of obligation for funds in BLI 1406. The voucher request date must occur before those funds are reported as obligated in LOCCS under the Obligation & Expenditure tab (24 CFR section 905.314(l)).
CONDITION
The Authority did not fully obligate and expend the Capital Fund Program grants and has not obligated at least 90 percent of the Capital Fund program grants within the 24-month deadline as follows:
2019 Capital Fund Program
2020 Capital Fund Program
2020 Emergency Capital Fund Program
In addition, the Authority did comply with the Capital Funds for Operating Costs requirement for 2019 Capital Fund Program.
CAUSE
The Authority was not aware of approaching obligation and expenditure deadlines and did not take appropriate or sufficient action to mitigate the loss of federal awards.
EFFECT
The Authority did not comply with the Period of Performance requirements.
QUESTIONED COSTS
None identified.
CONTEXT
The 2019 and 2020 CFP grant along with 2020 Emergency CFP grants were not obligated and expended within the applicable allowable period. The 2019 CFP grant funds transferred to operations were obligated before the voucher request was submitted.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority take immediate action to minimize the potential loss of Capital Fund Program grant funds and ensure that controls are in place to prevent deadlines from being missed for future Capital Fund grants. In addition, we recommend the grant fund voucher requests for operating transfers be submitted prior to funds being reported as obligated.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-004 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.871/14.879 – Housing Voucher Cluster
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
The unaudited FDS was required to be submitted to HUD by September 15, 2024.
CONDITION
The Authority’s unaudited FDS was submitted to HUD on September 16, 2024.
CAUSE
The Authority’s internal control processes were not sufficient to ensure timely filing of the unaudited FDS.
EFFECT
As a result of not submitting the FDS timely, HUD was limited in its ability to conduct proper monitoring and oversight of federal programs.
QUESTIONED COSTS
None identified.
CONTEXT
The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure its year-end closing process is sufficient to allow or
the timely filing of the unaudited FDS.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.
2024-005 – REPORTING
Significant Deficiency/Other Noncompliance
U.S. Department of Housing and Urban Development
ALN #: 14.872 – Public Housing Capital Fund
CRITERIA
HUD-53001, Actual Modernization Cost Certificate (AMCC) Capital Fund Program (OMB No. 2577-0157)
Report authority: 24 CFR 905.324 Data Reporting Requirements For modernization projects, the PHA shall submit the AMCC within 90 days after Expenditure End Date. To initiate the closeout process, the PHA shall submit the AMCC which details actual costs incurred between the DOFA date and the completion of the modernization project.
CONDITION
The Authority did not submit the AMCC for 2019 Capital Fund Program grant within 90 days after Expenditure End Date.
CAUSE
The Authority was not aware of approaching reporting deadlines and did not take appropriate or sufficient action to initiate the closeout process.
EFFECT
The Authority did not comply with the Reporting requirements.
QUESTIONED COSTS
None identified.
CONTEXT
The closeout process for 2019 CFP grant was not initiated within the 90 days after Expenditure
End Date.
REPEAT FINDING
Not a repeat finding.
RECOMMENDATION
We recommend that the Authority ensure that controls are in place to prevent reporting deadlines from being missed for future Capital Fund grants.
AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION
See Corrective Action Plan.