Audit 354004

Criteria or Specific Requirement: Eligibility The PHA must do the following: (1) As a condition of admission or continued occupancy, 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, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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 section 982.516). (3) 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 section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (4) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR section 982.516). (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). Condition: The Agency did not have adequate internal controls designed to ensure HCV eligibility requirements were being met. Questioned Costs: $120,680 Context: During the testing of the HCV tenant files for Eligibility, the following deficiencies were noted in 21 of 40 files: -21 instances where the annual certification was not processed within regulatory period of 12 months. -1 instance where a tenant’s income, assets, and expenses were not supported. Cause: The Agency failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative policy. Effect: The Agency is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months and documentation related to tenants income, assets and expenses. Repeat Finding: Yes, 2022-002 Recommendation: We recommend that management should implement a quality control review over a sampling of tenant files recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Eligibility The PHA must do the following: (1) As a condition of admission or continued occupancy, 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, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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 section 982.516). (3) 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 section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (4) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR section 982.516). (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). Condition: The Agency did not have adequate internal controls designed to ensure HCV eligibility requirements were being met. Questioned Costs: $120,680 Context: During the testing of the HCV tenant files for Eligibility, the following deficiencies were noted in 21 of 40 files: -21 instances where the annual certification was not processed within regulatory period of 12 months. -1 instance where a tenant’s income, assets, and expenses were not supported. Cause: The Agency failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative policy. Effect: The Agency is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months and documentation related to tenants income, assets and expenses. Repeat Finding: Yes, 2022-002 Recommendation: We recommend that management should implement a quality control review over a sampling of tenant files recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Eligibility The PHA must do the following: (1) As a condition of admission or continued occupancy, 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, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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 section 982.516). (3) 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 section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (4) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR section 982.516). (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). Condition: The Agency did not have adequate internal controls designed to ensure HCV eligibility requirements were being met. Questioned Costs: $120,680 Context: During the testing of the HCV tenant files for Eligibility, the following deficiencies were noted in 21 of 40 files: -21 instances where the annual certification was not processed within regulatory period of 12 months. -1 instance where a tenant’s income, assets, and expenses were not supported. Cause: The Agency failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative policy. Effect: The Agency is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months and documentation related to tenants income, assets and expenses. Repeat Finding: Yes, 2022-002 Recommendation: We recommend that management should implement a quality control review over a sampling of tenant files recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests and Provisions-Housing Quality Standards Enforcement For units under HAP contract that fail to meet HQS, the 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Agency did not have adequate internal controls designed to ensure that inspections were completed in accordance with HQS compliance requirements. Questioned Costs: None Context: During the testing of the HCV tenant files, certain special provision compliance deficiencies were noted in 4 of 40 files: -3 instances where the re-inspection was not completed and/or documented within 30 calendar days of the first failed inspection. -1 instance where the file did not contain documentation of the repairs have been made. -2 instances where the Agency failed to properly abate HAP payments after the second failed inspection. -1 instance where the Agency did not enforce its Administrative Plan-family obligations for tenant noncompliance. -1 instance where the file did not contain documentation showing the Agency provided landlord and tenant a notice of fail inspection. Cause: The Authority failed to follow their HQS Enforcement procedures. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: Yes, 2022-005 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests and Provisions-Housing Quality Standards Enforcement For units under HAP contract that fail to meet HQS, the 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Agency did not have adequate internal controls designed to ensure that inspections were completed in accordance with HQS compliance requirements. Questioned Costs: None Context: During the testing of the HCV tenant files, certain special provision compliance deficiencies were noted in 4 of 40 files: -3 instances where the re-inspection was not completed and/or documented within 30 calendar days of the first failed inspection. -1 instance where the file did not contain documentation of the repairs have been made. -2 instances where the Agency failed to properly abate HAP payments after the second failed inspection. -1 instance where the Agency did not enforce its Administrative Plan-family obligations for tenant noncompliance. -1 instance where the file did not contain documentation showing the Agency provided landlord and tenant a notice of fail inspection. Cause: The Authority failed to follow their HQS Enforcement procedures. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: Yes, 2022-005 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests and Provisions-Housing Quality Standards Enforcement For units under HAP contract that fail to meet HQS, the 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Agency did not have adequate internal controls designed to ensure that inspections were completed in accordance with HQS compliance requirements. Questioned Costs: None Context: During the testing of the HCV tenant files, certain special provision compliance deficiencies were noted in 4 of 40 files: -3 instances where the re-inspection was not completed and/or documented within 30 calendar days of the first failed inspection. -1 instance where the file did not contain documentation of the repairs have been made. -2 instances where the Agency failed to properly abate HAP payments after the second failed inspection. -1 instance where the Agency did not enforce its Administrative Plan-family obligations for tenant noncompliance. -1 instance where the file did not contain documentation showing the Agency provided landlord and tenant a notice of fail inspection. Cause: The Authority failed to follow their HQS Enforcement procedures. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: Yes, 2022-005 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Allowable Costs – Payroll In accordance with Uniform Grant Guidance (2 CFR Part 200), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Agency did not have adequate internal controls designed to ensure that allowable costs are recorded in accordance with compliance requirements. Questioned Costs: $392 Context: Out of the 40 files tested, 1 file was not charged to the correct program. Cause: The Agency did not sufficiently monitor controls to ensure compliance with payroll requirements. Effect: The Agency is not in compliance with federal regulations regarding allowable costs for payroll. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Agency reviews the controls in place to ensure that payroll transactions are charged to the correct program. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Allowable Costs – Payroll In accordance with Uniform Grant Guidance (2 CFR Part 200), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Agency did not have adequate internal controls designed to ensure that allowable costs are recorded in accordance with compliance requirements. Questioned Costs: $392 Context: Out of the 40 files tested, 1 file was not charged to the correct program. Cause: The Agency did not sufficiently monitor controls to ensure compliance with payroll requirements. Effect: The Agency is not in compliance with federal regulations regarding allowable costs for payroll. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Agency reviews the controls in place to ensure that payroll transactions are charged to the correct program. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Eligibility The PHA must do the following: (1) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR sections 960.253, 960.257, and 960.259). Condition: The Agency did not have adequate internal controls designed to ensure LIPH eligibility requirements were being met for City and County. Questioned Costs: Unable to determine. Context: Out of the 60 files tested, 2 were not reexamined timely in accordance with the compliance requirements. Cause: The Agency failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative policy. Effect: The Agency is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months. Repeat Finding: Yes, 2022-007 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Period of Performance For federal awards, costs must not be incurred prior to the start of the period of performance unless authorized by the federal awarding agency or the pass-through entity. Condition: The Agency did not have adequate internal controls designed to ensure that period of performance requirements were being met. Questioned Costs: $1,117 Context: Out of the 5 costs tested, one cost was incurred prior to the period performance start date. Cause: The Agency failed to adhere to the compliance requirements related to period of performance. Effect: The Agency is not in compliance with period of performance requirements. Repeat Finding: Not a repeat finding Recommendation: We recommend that management ensure that internal controls are in place and operating effectively for period of performance requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s complete payment request. This requirement also applies to each subrecipient that is a unit of general-purpose local government (24 CFR section 576.203). Condition: The Agency did not have adequate internal controls designed to ensure that subrecipient payments are paid in accordance with compliance requirements. Questioned Costs: None Context: Out of the 29 payments to subrecipients tested, 10 payments were not paid within 30 days. Cause: The Agency did not sufficiently monitor controls to ensure compliance with program requirements over payments to subrecipients. Effect: The Agency is not in compliance with federal regulations regarding subrecipient payments. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Agency reviews the controls in place to ensure that subrecipient payments are paid timely and within program requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s complete payment request. This requirement also applies to each subrecipient that is a unit of general-purpose local government (24 CFR section 576.203). Condition: The Agency did not have adequate internal controls designed to ensure that subrecipient payments are paid in accordance with compliance requirements. Questioned Costs: None Context: Out of the 29 payments to subrecipients tested, 10 payments were not paid within 30 days. Cause: The Agency did not sufficiently monitor controls to ensure compliance with program requirements over payments to subrecipients. Effect: The Agency is not in compliance with federal regulations regarding subrecipient payments. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Agency reviews the controls in place to ensure that subrecipient payments are paid timely and within program requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Earmarking The recipient may use up to 7.5 percent of its ESG program project costs for the payment of administrative costs related to the planning and execution of ESG activities (24 CFR section 576.108(a)). Condition: The Agency did not have adequate internal controls designed to ensure that earmarking requirements are met in accordance with compliance requirements. Questioned Costs: $37,140 Context: For the 2021 City ESG, the Agency drew $68,345 for administration of the $416,062 project costs or 16.4% of project costs. Cause: The Agency did not sufficiently monitor controls to ensure compliance with earmarking requirements. Effect: The Agency is not in compliance with earmarking requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that earmarking requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Earmarking The recipient may use up to 7.5 percent of its ESG program project costs for the payment of administrative costs related to the planning and execution of ESG activities (24 CFR section 576.108(a)). Condition: The Agency did not have adequate internal controls designed to ensure that earmarking requirements are met in accordance with compliance requirements. Questioned Costs: $37,140 Context: For the 2021 City ESG, the Agency drew $68,345 for administration of the $416,062 project costs or 16.4% of project costs. Cause: The Agency did not sufficiently monitor controls to ensure compliance with earmarking requirements. Effect: The Agency is not in compliance with earmarking requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that earmarking requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests Contracts for the construction of affordable housing with 12 or more HOME-assisted units are required to comply with the Wage Rate Requirements (42 USC 12836). Condition: The Agency did not have adequate internal controls designed to ensure that wage rate requirements are met in accordance with compliance requirements. Questioned Costs: None Context: During our testing, we noted the following exceptions related to wage rate requirements. • For two of the five projects, the Agency does not have a monitoring process in place to ensure that the consultant hired to perform the duties related to certified payrolls is done correctly and in compliance with federal requirements. • For one of the five projects, the Agency was unable to provide supporting documentation evidencing compliance with wage rate requirements. Cause: The Agency did not sufficiently monitor controls to ensure compliance with wage rate requirements. Effect: The Agency is not in compliance with wage rate requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that wage rate requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests Contracts for the construction of affordable housing with 12 or more HOME-assisted units are required to comply with the Wage Rate Requirements (42 USC 12836). Condition: The Agency did not have adequate internal controls designed to ensure that wage rate requirements are met in accordance with compliance requirements. Questioned Costs: None Context: During our testing, we noted the following exceptions related to wage rate requirements. • For two of the five projects, the Agency does not have a monitoring process in place to ensure that the consultant hired to perform the duties related to certified payrolls is done correctly and in compliance with federal requirements. • For one of the five projects, the Agency was unable to provide supporting documentation evidencing compliance with wage rate requirements. Cause: The Agency did not sufficiently monitor controls to ensure compliance with wage rate requirements. Effect: The Agency is not in compliance with wage rate requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that wage rate requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests Contracts for the construction of affordable housing with 12 or more HOME-assisted units are required to comply with the Wage Rate Requirements (42 USC 12836). Condition: The Agency did not have adequate internal controls designed to ensure that wage rate requirements are met in accordance with compliance requirements. Questioned Costs: None Context: During our testing, we noted the following exceptions related to wage rate requirements. • For two of the five projects, the Agency does not have a monitoring process in place to ensure that the consultant hired to perform the duties related to certified payrolls is done correctly and in compliance with federal requirements. • For one of the five projects, the Agency was unable to provide supporting documentation evidencing compliance with wage rate requirements. Cause: The Agency did not sufficiently monitor controls to ensure compliance with wage rate requirements. Effect: The Agency is not in compliance with wage rate requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that wage rate requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Eligibility The PHA must do the following: (1) As a condition of admission or continued occupancy, 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, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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 section 982.516). (3) 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 section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (4) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR section 982.516). (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). Condition: The Agency did not have adequate internal controls designed to ensure HCV eligibility requirements were being met. Questioned Costs: $120,680 Context: During the testing of the HCV tenant files for Eligibility, the following deficiencies were noted in 21 of 40 files: -21 instances where the annual certification was not processed within regulatory period of 12 months. -1 instance where a tenant’s income, assets, and expenses were not supported. Cause: The Agency failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative policy. Effect: The Agency is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months and documentation related to tenants income, assets and expenses. Repeat Finding: Yes, 2022-002 Recommendation: We recommend that management should implement a quality control review over a sampling of tenant files recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Eligibility The PHA must do the following: (1) As a condition of admission or continued occupancy, 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, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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 section 982.516). (3) 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 section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (4) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR section 982.516). (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). Condition: The Agency did not have adequate internal controls designed to ensure HCV eligibility requirements were being met. Questioned Costs: $120,680 Context: During the testing of the HCV tenant files for Eligibility, the following deficiencies were noted in 21 of 40 files: -21 instances where the annual certification was not processed within regulatory period of 12 months. -1 instance where a tenant’s income, assets, and expenses were not supported. Cause: The Agency failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative policy. Effect: The Agency is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months and documentation related to tenants income, assets and expenses. Repeat Finding: Yes, 2022-002 Recommendation: We recommend that management should implement a quality control review over a sampling of tenant files recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Eligibility The PHA must do the following: (1) As a condition of admission or continued occupancy, 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, 5.609, and 982.516). (2) For both family income examinations and reexaminations, 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 section 982.516). (3) 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 section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). (4) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR section 982.516). (5) Select tenants from the HCVP waiting list (see III.N.1, “Special Tests and Provisions – Selection from the Waiting List”) (24 CFR sections 982.202 through 982.207). Condition: The Agency did not have adequate internal controls designed to ensure HCV eligibility requirements were being met. Questioned Costs: $120,680 Context: During the testing of the HCV tenant files for Eligibility, the following deficiencies were noted in 21 of 40 files: -21 instances where the annual certification was not processed within regulatory period of 12 months. -1 instance where a tenant’s income, assets, and expenses were not supported. Cause: The Agency failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative policy. Effect: The Agency is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months and documentation related to tenants income, assets and expenses. Repeat Finding: Yes, 2022-002 Recommendation: We recommend that management should implement a quality control review over a sampling of tenant files recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests and Provisions-Housing Quality Standards Enforcement For units under HAP contract that fail to meet HQS, the 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Agency did not have adequate internal controls designed to ensure that inspections were completed in accordance with HQS compliance requirements. Questioned Costs: None Context: During the testing of the HCV tenant files, certain special provision compliance deficiencies were noted in 4 of 40 files: -3 instances where the re-inspection was not completed and/or documented within 30 calendar days of the first failed inspection. -1 instance where the file did not contain documentation of the repairs have been made. -2 instances where the Agency failed to properly abate HAP payments after the second failed inspection. -1 instance where the Agency did not enforce its Administrative Plan-family obligations for tenant noncompliance. -1 instance where the file did not contain documentation showing the Agency provided landlord and tenant a notice of fail inspection. Cause: The Authority failed to follow their HQS Enforcement procedures. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: Yes, 2022-005 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests and Provisions-Housing Quality Standards Enforcement For units under HAP contract that fail to meet HQS, the 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Agency did not have adequate internal controls designed to ensure that inspections were completed in accordance with HQS compliance requirements. Questioned Costs: None Context: During the testing of the HCV tenant files, certain special provision compliance deficiencies were noted in 4 of 40 files: -3 instances where the re-inspection was not completed and/or documented within 30 calendar days of the first failed inspection. -1 instance where the file did not contain documentation of the repairs have been made. -2 instances where the Agency failed to properly abate HAP payments after the second failed inspection. -1 instance where the Agency did not enforce its Administrative Plan-family obligations for tenant noncompliance. -1 instance where the file did not contain documentation showing the Agency provided landlord and tenant a notice of fail inspection. Cause: The Authority failed to follow their HQS Enforcement procedures. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: Yes, 2022-005 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests and Provisions-Housing Quality Standards Enforcement For units under HAP contract that fail to meet HQS, the 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 abate HAP payments beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: The Agency did not have adequate internal controls designed to ensure that inspections were completed in accordance with HQS compliance requirements. Questioned Costs: None Context: During the testing of the HCV tenant files, certain special provision compliance deficiencies were noted in 4 of 40 files: -3 instances where the re-inspection was not completed and/or documented within 30 calendar days of the first failed inspection. -1 instance where the file did not contain documentation of the repairs have been made. -2 instances where the Agency failed to properly abate HAP payments after the second failed inspection. -1 instance where the Agency did not enforce its Administrative Plan-family obligations for tenant noncompliance. -1 instance where the file did not contain documentation showing the Agency provided landlord and tenant a notice of fail inspection. Cause: The Authority failed to follow their HQS Enforcement procedures. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: Yes, 2022-005 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Allowable Costs – Payroll In accordance with Uniform Grant Guidance (2 CFR Part 200), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Agency did not have adequate internal controls designed to ensure that allowable costs are recorded in accordance with compliance requirements. Questioned Costs: $392 Context: Out of the 40 files tested, 1 file was not charged to the correct program. Cause: The Agency did not sufficiently monitor controls to ensure compliance with payroll requirements. Effect: The Agency is not in compliance with federal regulations regarding allowable costs for payroll. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Agency reviews the controls in place to ensure that payroll transactions are charged to the correct program. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Allowable Costs – Payroll In accordance with Uniform Grant Guidance (2 CFR Part 200), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Agency did not have adequate internal controls designed to ensure that allowable costs are recorded in accordance with compliance requirements. Questioned Costs: $392 Context: Out of the 40 files tested, 1 file was not charged to the correct program. Cause: The Agency did not sufficiently monitor controls to ensure compliance with payroll requirements. Effect: The Agency is not in compliance with federal regulations regarding allowable costs for payroll. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Agency reviews the controls in place to ensure that payroll transactions are charged to the correct program. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Eligibility The PHA must do the following: (1) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR sections 960.253, 960.257, and 960.259). Condition: The Agency did not have adequate internal controls designed to ensure LIPH eligibility requirements were being met for City and County. Questioned Costs: Unable to determine. Context: Out of the 60 files tested, 2 were not reexamined timely in accordance with the compliance requirements. Cause: The Agency failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative policy. Effect: The Agency is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months. Repeat Finding: Yes, 2022-007 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Period of Performance For federal awards, costs must not be incurred prior to the start of the period of performance unless authorized by the federal awarding agency or the pass-through entity. Condition: The Agency did not have adequate internal controls designed to ensure that period of performance requirements were being met. Questioned Costs: $1,117 Context: Out of the 5 costs tested, one cost was incurred prior to the period performance start date. Cause: The Agency failed to adhere to the compliance requirements related to period of performance. Effect: The Agency is not in compliance with period of performance requirements. Repeat Finding: Not a repeat finding Recommendation: We recommend that management ensure that internal controls are in place and operating effectively for period of performance requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s complete payment request. This requirement also applies to each subrecipient that is a unit of general-purpose local government (24 CFR section 576.203). Condition: The Agency did not have adequate internal controls designed to ensure that subrecipient payments are paid in accordance with compliance requirements. Questioned Costs: None Context: Out of the 29 payments to subrecipients tested, 10 payments were not paid within 30 days. Cause: The Agency did not sufficiently monitor controls to ensure compliance with program requirements over payments to subrecipients. Effect: The Agency is not in compliance with federal regulations regarding subrecipient payments. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Agency reviews the controls in place to ensure that subrecipient payments are paid timely and within program requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s complete payment request. This requirement also applies to each subrecipient that is a unit of general-purpose local government (24 CFR section 576.203). Condition: The Agency did not have adequate internal controls designed to ensure that subrecipient payments are paid in accordance with compliance requirements. Questioned Costs: None Context: Out of the 29 payments to subrecipients tested, 10 payments were not paid within 30 days. Cause: The Agency did not sufficiently monitor controls to ensure compliance with program requirements over payments to subrecipients. Effect: The Agency is not in compliance with federal regulations regarding subrecipient payments. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Agency reviews the controls in place to ensure that subrecipient payments are paid timely and within program requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Agency did not submit the required Federal Funding Accountably and Transparency Act reports for the first-tier subawards from funding received under the program. Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None Effect: Noncompliance with reporting requirements for the federal program. Context: Federal Funding Accountability and Transparency Act reporting was not submitted related to first-tier subrecipients. Cause: The program manager did not know that additional reporting was required and still didn’t think it was required for the Agency. Repeat Finding: Yes, 2022-008 Recommendation: We recommend that the Agency provide additional training to program managers regarding the reporting requirements of the grant to ensure compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Earmarking The recipient may use up to 7.5 percent of its ESG program project costs for the payment of administrative costs related to the planning and execution of ESG activities (24 CFR section 576.108(a)). Condition: The Agency did not have adequate internal controls designed to ensure that earmarking requirements are met in accordance with compliance requirements. Questioned Costs: $37,140 Context: For the 2021 City ESG, the Agency drew $68,345 for administration of the $416,062 project costs or 16.4% of project costs. Cause: The Agency did not sufficiently monitor controls to ensure compliance with earmarking requirements. Effect: The Agency is not in compliance with earmarking requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that earmarking requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Earmarking The recipient may use up to 7.5 percent of its ESG program project costs for the payment of administrative costs related to the planning and execution of ESG activities (24 CFR section 576.108(a)). Condition: The Agency did not have adequate internal controls designed to ensure that earmarking requirements are met in accordance with compliance requirements. Questioned Costs: $37,140 Context: For the 2021 City ESG, the Agency drew $68,345 for administration of the $416,062 project costs or 16.4% of project costs. Cause: The Agency did not sufficiently monitor controls to ensure compliance with earmarking requirements. Effect: The Agency is not in compliance with earmarking requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that earmarking requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests Contracts for the construction of affordable housing with 12 or more HOME-assisted units are required to comply with the Wage Rate Requirements (42 USC 12836). Condition: The Agency did not have adequate internal controls designed to ensure that wage rate requirements are met in accordance with compliance requirements. Questioned Costs: None Context: During our testing, we noted the following exceptions related to wage rate requirements. • For two of the five projects, the Agency does not have a monitoring process in place to ensure that the consultant hired to perform the duties related to certified payrolls is done correctly and in compliance with federal requirements. • For one of the five projects, the Agency was unable to provide supporting documentation evidencing compliance with wage rate requirements. Cause: The Agency did not sufficiently monitor controls to ensure compliance with wage rate requirements. Effect: The Agency is not in compliance with wage rate requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that wage rate requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests Contracts for the construction of affordable housing with 12 or more HOME-assisted units are required to comply with the Wage Rate Requirements (42 USC 12836). Condition: The Agency did not have adequate internal controls designed to ensure that wage rate requirements are met in accordance with compliance requirements. Questioned Costs: None Context: During our testing, we noted the following exceptions related to wage rate requirements. • For two of the five projects, the Agency does not have a monitoring process in place to ensure that the consultant hired to perform the duties related to certified payrolls is done correctly and in compliance with federal requirements. • For one of the five projects, the Agency was unable to provide supporting documentation evidencing compliance with wage rate requirements. Cause: The Agency did not sufficiently monitor controls to ensure compliance with wage rate requirements. Effect: The Agency is not in compliance with wage rate requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that wage rate requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Special Tests Contracts for the construction of affordable housing with 12 or more HOME-assisted units are required to comply with the Wage Rate Requirements (42 USC 12836). Condition: The Agency did not have adequate internal controls designed to ensure that wage rate requirements are met in accordance with compliance requirements. Questioned Costs: None Context: During our testing, we noted the following exceptions related to wage rate requirements. • For two of the five projects, the Agency does not have a monitoring process in place to ensure that the consultant hired to perform the duties related to certified payrolls is done correctly and in compliance with federal requirements. • For one of the five projects, the Agency was unable to provide supporting documentation evidencing compliance with wage rate requirements. Cause: The Agency did not sufficiently monitor controls to ensure compliance with wage rate requirements. Effect: The Agency is not in compliance with wage rate requirements. Repeat Finding: No Recommendation: We recommend that the Agency reviews the controls in place to ensure that wage rate requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.