Audit 357879

FY End
2024-12-31
Total Expended
$10.88M
Findings
14
Programs
9
Year: 2024 Accepted: 2025-06-03
Auditor: Hawkins Ash CPAS

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
563602 2024-003 Significant Deficiency - C
563603 2024-001 Material Weakness Yes N
563604 2024-002 Material Weakness - N
563605 2024-001 Material Weakness Yes N
563606 2024-002 Material Weakness - N
563607 2024-001 Material Weakness Yes N
563608 2024-002 Material Weakness - N
1140044 2024-003 Significant Deficiency - C
1140045 2024-001 Material Weakness Yes N
1140046 2024-002 Material Weakness - N
1140047 2024-001 Material Weakness Yes N
1140048 2024-002 Material Weakness - N
1140049 2024-001 Material Weakness Yes N
1140050 2024-002 Material Weakness - N

Programs

ALN Program Spent Major Findings
14.871 Section 8 Housing Choice Vouchers $1.08M Yes 2
14.872 Public Housing Capital Fund $971,926 Yes 1
14.879 Mainstream Vouchers $852,076 Yes 2
14.181 Supportive Housing for Persons with Disabilities $647,200 - 0
14.267 Continuum of Care Program $535,611 - 0
14.850 Public Housing Operating Fund $363,989 - 0
14.149 Rent Supplements Rental Housing for Lower Income Families $49,833 - 0
10.427 Rural Rental Assistance Payments $28,970 - 0
10.415 Rural Rental Housing Loans $17,607 - 0

Contacts

Name Title Type
GQWAYD787CC8 Karla Strain Auditee
5073286369 Joe Haas Auditor
No contacts on file

Notes to SEFA

Title: REPORTING ENTITY Accounting Policies: Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Olmsted County Housing and Redevelopment Authority has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The Schedule of Expenditures of Federal Awards presents the activities of federal award programs expended by the Olmsted County Housing and Redevelopment Authority. The Authority’s reporting entity is defined in Note A to the financial statements.
Title: BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Olmsted County Housing and Redevelopment Authority has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards includes the federal grant activity of Olmsted County Housing and Redevelopment Authority under programs of the federal government for the year ended December 31, 2024. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the presentation of, the financial statements. Because the schedule presents only a selected portion of the operations of Olmsted County Housing and Redevelopment Authority, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Olmsted County Housing and Redevelopment Authority.
Title: DISCLOSURE OF OTHER FORMS OF ASSISTANCE Accounting Policies: Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Olmsted County Housing and Redevelopment Authority has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The Olmsted County Housing and Redevelopment Authority had non-cash assistance in the form of interest subsidy in the amount of $17,607 from Rural Rental Housing loans during the year ending December 31, 2024.
Title: RECONCILIATION TO SCHEDULE OF INTERGOVERNMENTAL REVENUE Accounting Policies: Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Olmsted County Housing and Redevelopment Authority has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Federal grant revenue per Schedule of Intergovernmental Revenue $ 9,160,657 Per HUD include in SEFA Other public housing authorities, port in income 1,075,898 Supportive housing for persons with disabilities, temporarily restricted capital advance 647,200 Expenditures per Schedule of Expenditures of Federal Awards $ 10,883,755

Finding Details

Program: Public Housing Capital Fund Requirement: When expending capital funds the Authority cannot expend nonfederal funds first to pay the applicable bills and then use Capital Funds to reimburse themselves (Capital Fund Handbook). Condition: During review of capital fund cash management procedures it was determined that the Authority was using non-federal funds to pay for Capital Fund expenditures and then drawing Capital Funds to reimburse itself. Cause: The Authority does not have the appropriate internal controls in place to ensure that Cash Management procedures are done in accordance with HUD requirements. Effect: Capital Fund cash management draws are not being completed in accordance with the Capital Fund Handbook requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: New deficiency in the current year. Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that Cash Management draws are being done in accordance with the HUD Capital Fund Handbook. Management’s Response: In response to these findings, the Authority has reviewed and revised its Capital Fund cash management procedures to ensure full compliance with the Capital Fund Handbook. The updated procedures have been reviewed in collaboration with both the Housing Project Manager and the Housing Program Manager. Invoices will be organized to fulfil the monthly obligation and paid within three days of the fund draw. To prevent recurrence and ensure ongoing compliance, the Authority will hold monthly meetings to review project timelines and cash flow needs. Communication frequency will increase during complex, multi-phase projects to support effective oversight and coordination. Furthermore, updated policy and payment procedures will be clearly communicated to all current and future vendors to ensure alignment with federal regulations. These corrective actions reflect the Authority’s commitment to improved financial oversight and adherence to all applicable funding regulations.
Program: Housing Vouchers Cluster Requirement: Housing Quality Standards Inspections and enforcement must be done in accordance with HUD requirements. Condition: HQS Inspections were not completed timely and HUD HQS enforcement standards were not followed for tenants that failed HQS re-inspections. Cause: The Authority does not have the appropriate internal controls in place to ensure that HQS inspection and enforcement requirements are being implemented and followed. Effect: HQS inspections, tenant enforcement and abatement are not being done in accordance with HUD requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: 2023-001 Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that HQS inspections and re-inspections are completed in accordance with HUD requirements. Furthermore to take prompt action on tenant enforcement and/or landlord abatement for failed re-inspections. Management’s Response: Monthly reports for failed inspections were set up in May of 2024 in response to the previous year’s finding. While these reports were helpful, they did not fully resolve the issue. Two additional changes have since been implemented: 1) Staffing changes including the removal of one Specialist that had a high frequency of missed follow-ups and the addition of a “Lead” Housing Specialist; 2) The Lead Housing Specialist is now receiving all-staff monthly reports on failed HQS inspections to ensure that follow-up is not only completed by completed timely. We expect a drastic improvement in this category.
Program: Housing Vouchers Cluster Requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published fair market rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is reasonable (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During review of Housing Voucher new admission and recertification tenant files it was found that reasonable rent tests were not being done on the majority of the new applications and tenant recertifications. Cause: The Authority does not have the appropriate internal controls in place to ensure that Reasonable Rent tests are being documented in completed in accordance with HUD requirements. Effect: Without Reasonable Rent tests being completed, the Authority is not in compliance with HUD’s new admission and recertification requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: New deficiency in the current year. Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that Reasonable Rent tests are completed and documented on all new admissions and tenant recertifications that require them. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated.
Program: Housing Vouchers Cluster Requirement: Housing Quality Standards Inspections and enforcement must be done in accordance with HUD requirements. Condition: HQS Inspections were not completed timely and HUD HQS enforcement standards were not followed for tenants that failed HQS re-inspections. Cause: The Authority does not have the appropriate internal controls in place to ensure that HQS inspection and enforcement requirements are being implemented and followed. Effect: HQS inspections, tenant enforcement and abatement are not being done in accordance with HUD requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: 2023-001 Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that HQS inspections and re-inspections are completed in accordance with HUD requirements. Furthermore to take prompt action on tenant enforcement and/or landlord abatement for failed re-inspections. Management’s Response: Monthly reports for failed inspections were set up in May of 2024 in response to the previous year’s finding. While these reports were helpful, they did not fully resolve the issue. Two additional changes have since been implemented: 1) Staffing changes including the removal of one Specialist that had a high frequency of missed follow-ups and the addition of a “Lead” Housing Specialist; 2) The Lead Housing Specialist is now receiving all-staff monthly reports on failed HQS inspections to ensure that follow-up is not only completed by completed timely. We expect a drastic improvement in this category.
Program: Housing Vouchers Cluster Requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published fair market rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is reasonable (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During review of Housing Voucher new admission and recertification tenant files it was found that reasonable rent tests were not being done on the majority of the new applications and tenant recertifications. Cause: The Authority does not have the appropriate internal controls in place to ensure that Reasonable Rent tests are being documented in completed in accordance with HUD requirements. Effect: Without Reasonable Rent tests being completed, the Authority is not in compliance with HUD’s new admission and recertification requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: New deficiency in the current year. Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that Reasonable Rent tests are completed and documented on all new admissions and tenant recertifications that require them. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated.
Program: Housing Vouchers Cluster Requirement: Housing Quality Standards Inspections and enforcement must be done in accordance with HUD requirements. Condition: HQS Inspections were not completed timely and HUD HQS enforcement standards were not followed for tenants that failed HQS re-inspections. Cause: The Authority does not have the appropriate internal controls in place to ensure that HQS inspection and enforcement requirements are being implemented and followed. Effect: HQS inspections, tenant enforcement and abatement are not being done in accordance with HUD requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: 2023-001 Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that HQS inspections and re-inspections are completed in accordance with HUD requirements. Furthermore to take prompt action on tenant enforcement and/or landlord abatement for failed re-inspections. Management’s Response: Monthly reports for failed inspections were set up in May of 2024 in response to the previous year’s finding. While these reports were helpful, they did not fully resolve the issue. Two additional changes have since been implemented: 1) Staffing changes including the removal of one Specialist that had a high frequency of missed follow-ups and the addition of a “Lead” Housing Specialist; 2) The Lead Housing Specialist is now receiving all-staff monthly reports on failed HQS inspections to ensure that follow-up is not only completed by completed timely. We expect a drastic improvement in this category.
Program: Housing Vouchers Cluster Requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published fair market rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is reasonable (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During review of Housing Voucher new admission and recertification tenant files it was found that reasonable rent tests were not being done on the majority of the new applications and tenant recertifications. Cause: The Authority does not have the appropriate internal controls in place to ensure that Reasonable Rent tests are being documented in completed in accordance with HUD requirements. Effect: Without Reasonable Rent tests being completed, the Authority is not in compliance with HUD’s new admission and recertification requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: New deficiency in the current year. Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that Reasonable Rent tests are completed and documented on all new admissions and tenant recertifications that require them. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated.
Program: Public Housing Capital Fund Requirement: When expending capital funds the Authority cannot expend nonfederal funds first to pay the applicable bills and then use Capital Funds to reimburse themselves (Capital Fund Handbook). Condition: During review of capital fund cash management procedures it was determined that the Authority was using non-federal funds to pay for Capital Fund expenditures and then drawing Capital Funds to reimburse itself. Cause: The Authority does not have the appropriate internal controls in place to ensure that Cash Management procedures are done in accordance with HUD requirements. Effect: Capital Fund cash management draws are not being completed in accordance with the Capital Fund Handbook requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: New deficiency in the current year. Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that Cash Management draws are being done in accordance with the HUD Capital Fund Handbook. Management’s Response: In response to these findings, the Authority has reviewed and revised its Capital Fund cash management procedures to ensure full compliance with the Capital Fund Handbook. The updated procedures have been reviewed in collaboration with both the Housing Project Manager and the Housing Program Manager. Invoices will be organized to fulfil the monthly obligation and paid within three days of the fund draw. To prevent recurrence and ensure ongoing compliance, the Authority will hold monthly meetings to review project timelines and cash flow needs. Communication frequency will increase during complex, multi-phase projects to support effective oversight and coordination. Furthermore, updated policy and payment procedures will be clearly communicated to all current and future vendors to ensure alignment with federal regulations. These corrective actions reflect the Authority’s commitment to improved financial oversight and adherence to all applicable funding regulations.
Program: Housing Vouchers Cluster Requirement: Housing Quality Standards Inspections and enforcement must be done in accordance with HUD requirements. Condition: HQS Inspections were not completed timely and HUD HQS enforcement standards were not followed for tenants that failed HQS re-inspections. Cause: The Authority does not have the appropriate internal controls in place to ensure that HQS inspection and enforcement requirements are being implemented and followed. Effect: HQS inspections, tenant enforcement and abatement are not being done in accordance with HUD requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: 2023-001 Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that HQS inspections and re-inspections are completed in accordance with HUD requirements. Furthermore to take prompt action on tenant enforcement and/or landlord abatement for failed re-inspections. Management’s Response: Monthly reports for failed inspections were set up in May of 2024 in response to the previous year’s finding. While these reports were helpful, they did not fully resolve the issue. Two additional changes have since been implemented: 1) Staffing changes including the removal of one Specialist that had a high frequency of missed follow-ups and the addition of a “Lead” Housing Specialist; 2) The Lead Housing Specialist is now receiving all-staff monthly reports on failed HQS inspections to ensure that follow-up is not only completed by completed timely. We expect a drastic improvement in this category.
Program: Housing Vouchers Cluster Requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published fair market rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is reasonable (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During review of Housing Voucher new admission and recertification tenant files it was found that reasonable rent tests were not being done on the majority of the new applications and tenant recertifications. Cause: The Authority does not have the appropriate internal controls in place to ensure that Reasonable Rent tests are being documented in completed in accordance with HUD requirements. Effect: Without Reasonable Rent tests being completed, the Authority is not in compliance with HUD’s new admission and recertification requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: New deficiency in the current year. Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that Reasonable Rent tests are completed and documented on all new admissions and tenant recertifications that require them. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated.
Program: Housing Vouchers Cluster Requirement: Housing Quality Standards Inspections and enforcement must be done in accordance with HUD requirements. Condition: HQS Inspections were not completed timely and HUD HQS enforcement standards were not followed for tenants that failed HQS re-inspections. Cause: The Authority does not have the appropriate internal controls in place to ensure that HQS inspection and enforcement requirements are being implemented and followed. Effect: HQS inspections, tenant enforcement and abatement are not being done in accordance with HUD requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: 2023-001 Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that HQS inspections and re-inspections are completed in accordance with HUD requirements. Furthermore to take prompt action on tenant enforcement and/or landlord abatement for failed re-inspections. Management’s Response: Monthly reports for failed inspections were set up in May of 2024 in response to the previous year’s finding. While these reports were helpful, they did not fully resolve the issue. Two additional changes have since been implemented: 1) Staffing changes including the removal of one Specialist that had a high frequency of missed follow-ups and the addition of a “Lead” Housing Specialist; 2) The Lead Housing Specialist is now receiving all-staff monthly reports on failed HQS inspections to ensure that follow-up is not only completed by completed timely. We expect a drastic improvement in this category.
Program: Housing Vouchers Cluster Requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published fair market rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is reasonable (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During review of Housing Voucher new admission and recertification tenant files it was found that reasonable rent tests were not being done on the majority of the new applications and tenant recertifications. Cause: The Authority does not have the appropriate internal controls in place to ensure that Reasonable Rent tests are being documented in completed in accordance with HUD requirements. Effect: Without Reasonable Rent tests being completed, the Authority is not in compliance with HUD’s new admission and recertification requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: New deficiency in the current year. Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that Reasonable Rent tests are completed and documented on all new admissions and tenant recertifications that require them. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated.
Program: Housing Vouchers Cluster Requirement: Housing Quality Standards Inspections and enforcement must be done in accordance with HUD requirements. Condition: HQS Inspections were not completed timely and HUD HQS enforcement standards were not followed for tenants that failed HQS re-inspections. Cause: The Authority does not have the appropriate internal controls in place to ensure that HQS inspection and enforcement requirements are being implemented and followed. Effect: HQS inspections, tenant enforcement and abatement are not being done in accordance with HUD requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: 2023-001 Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that HQS inspections and re-inspections are completed in accordance with HUD requirements. Furthermore to take prompt action on tenant enforcement and/or landlord abatement for failed re-inspections. Management’s Response: Monthly reports for failed inspections were set up in May of 2024 in response to the previous year’s finding. While these reports were helpful, they did not fully resolve the issue. Two additional changes have since been implemented: 1) Staffing changes including the removal of one Specialist that had a high frequency of missed follow-ups and the addition of a “Lead” Housing Specialist; 2) The Lead Housing Specialist is now receiving all-staff monthly reports on failed HQS inspections to ensure that follow-up is not only completed by completed timely. We expect a drastic improvement in this category.
Program: Housing Vouchers Cluster Requirement: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published fair market rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is reasonable (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During review of Housing Voucher new admission and recertification tenant files it was found that reasonable rent tests were not being done on the majority of the new applications and tenant recertifications. Cause: The Authority does not have the appropriate internal controls in place to ensure that Reasonable Rent tests are being documented in completed in accordance with HUD requirements. Effect: Without Reasonable Rent tests being completed, the Authority is not in compliance with HUD’s new admission and recertification requirements. Questioned Cost: Not applicable. Information: Sampling was statistically valid and a systemic problem. Prior Year Finding: New deficiency in the current year. Recommendation: It is recommended that the Authority implements and applies the appropriate controls to ensure that Reasonable Rent tests are completed and documented on all new admissions and tenant recertifications that require them. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated. Management’s Response: An evaluation has been completed to determine the gaps in staff training on this topic. For the staff struggling with this area, step-by-step instruction has been provided and on-going weekly mentoring with the Program Manager initiated. Significant improvement in this category is anticipated.