Audit 359660

Finding 2024 – 001 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). 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) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 4 The file is missing support for the calculation of HAP. Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 18 The EIV was missing from the file. 3 The file was missing the HUD-9886 authorization form. 3 The file was missing the Authority’s general release form. 12 The Authority did not review the tenant’s information on an annual basis 5 The allowable expenditures included in the file were not included on the 50058 9 The HAP paid was understated 2 The HAP income information reported in the 50058 did not agree to support. Questioned Costs: $12,428 Context: Out of 60 housing voucher cluster tenant files tested, 32 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, 2022-001, and 2023-001. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Conduct training for program staff on eligibility documentation requirements and program rules. 2. Initiate internal audits of tenant files to identify and correct documentation issues proactively. 3. Establish a monitoring protocol to ensure continued compliance and to prevent recurrence of documentation issues. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 001 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). 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) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 4 The file is missing support for the calculation of HAP. Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 18 The EIV was missing from the file. 3 The file was missing the HUD-9886 authorization form. 3 The file was missing the Authority’s general release form. 12 The Authority did not review the tenant’s information on an annual basis 5 The allowable expenditures included in the file were not included on the 50058 9 The HAP paid was understated 2 The HAP income information reported in the 50058 did not agree to support. Questioned Costs: $12,428 Context: Out of 60 housing voucher cluster tenant files tested, 32 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, 2022-001, and 2023-001. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Conduct training for program staff on eligibility documentation requirements and program rules. 2. Initiate internal audits of tenant files to identify and correct documentation issues proactively. 3. Establish a monitoring protocol to ensure continued compliance and to prevent recurrence of documentation issues. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 001 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). 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) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 4 The file is missing support for the calculation of HAP. Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 18 The EIV was missing from the file. 3 The file was missing the HUD-9886 authorization form. 3 The file was missing the Authority’s general release form. 12 The Authority did not review the tenant’s information on an annual basis 5 The allowable expenditures included in the file were not included on the 50058 9 The HAP paid was understated 2 The HAP income information reported in the 50058 did not agree to support. Questioned Costs: $12,428 Context: Out of 60 housing voucher cluster tenant files tested, 32 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, 2022-001, and 2023-001. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Conduct training for program staff on eligibility documentation requirements and program rules. 2. Initiate internal audits of tenant files to identify and correct documentation issues proactively. 3. Establish a monitoring protocol to ensure continued compliance and to prevent recurrence of documentation issues. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 002 – Annual HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters Criteria or Specific Requirement: The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During the testing of 60 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Annual HQS Inspections Number of Instances Finding 2 The HQS inspection was not performed in a timely manner Questioned Costs: Undeterminable Context: Out of 60 files tested for annual inspections, 2 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, 2022-002, and 2023-002. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Implement a centralized tracking system to monitor inspection due dates and follow-up timelines to ensure all inspections are completed within the HUD-mandated timeframes. 2. Evaluate staffing levels and consider hiring additional inspectors or contracting third-party services to meet inspection demands. 3. Provide ongoing training on HQS protocols and compliance expectations. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 002 – Annual HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters Criteria or Specific Requirement: The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During the testing of 60 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Annual HQS Inspections Number of Instances Finding 2 The HQS inspection was not performed in a timely manner Questioned Costs: Undeterminable Context: Out of 60 files tested for annual inspections, 2 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, 2022-002, and 2023-002. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Implement a centralized tracking system to monitor inspection due dates and follow-up timelines to ensure all inspections are completed within the HUD-mandated timeframes. 2. Evaluate staffing levels and consider hiring additional inspectors or contracting third-party services to meet inspection demands. 3. Provide ongoing training on HQS protocols and compliance expectations. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 002 – Annual HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters Criteria or Specific Requirement: The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During the testing of 60 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Annual HQS Inspections Number of Instances Finding 2 The HQS inspection was not performed in a timely manner Questioned Costs: Undeterminable Context: Out of 60 files tested for annual inspections, 2 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, 2022-002, and 2023-002. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Implement a centralized tracking system to monitor inspection due dates and follow-up timelines to ensure all inspections are completed within the HUD-mandated timeframes. 2. Evaluate staffing levels and consider hiring additional inspectors or contracting third-party services to meet inspection demands. 3. Provide ongoing training on HQS protocols and compliance expectations. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 003 – Rent Reasonableness Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance,Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA 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 a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of 80 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 1 The rent reasonableness was not performed prior to the effective date. Questioned Costs: Undeterminable Context: During our testing, we reviewed 80 tenant files that required rent reasonableness determinations; 1 tenant file contained errors as noted above. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unreasonable rent to the landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, 2022-003, and 2023-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 003 – Rent Reasonableness Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance,Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA 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 a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of 80 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 1 The rent reasonableness was not performed prior to the effective date. Questioned Costs: Undeterminable Context: During our testing, we reviewed 80 tenant files that required rent reasonableness determinations; 1 tenant file contained errors as noted above. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unreasonable rent to the landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, 2022-003, and 2023-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 003 – Rent Reasonableness Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance,Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA 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 a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of 80 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 1 The rent reasonableness was not performed prior to the effective date. Questioned Costs: Undeterminable Context: During our testing, we reviewed 80 tenant files that required rent reasonableness determinations; 1 tenant file contained errors as noted above. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unreasonable rent to the landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, 2022-003, and 2023-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 004 – Selection from the Waiting List Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (nonwaiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Tenant Selected from the Waiting List Number of Instances Finding 6 The tenant was not removed from the waitlist in accordance with policy. Questioned Costs: Undeterminable Context: Out of 60 tenants selected from the waiting list files tested, 6 files contained the errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, 2022-004, and 2023-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are removed from the waiting list timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 004 – Selection from the Waiting List Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (nonwaiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Tenant Selected from the Waiting List Number of Instances Finding 6 The tenant was not removed from the waitlist in accordance with policy. Questioned Costs: Undeterminable Context: Out of 60 tenants selected from the waiting list files tested, 6 files contained the errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, 2022-004, and 2023-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are removed from the waiting list timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 004 – Selection from the Waiting List Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (nonwaiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Tenant Selected from the Waiting List Number of Instances Finding 6 The tenant was not removed from the waitlist in accordance with policy. Questioned Costs: Undeterminable Context: Out of 60 tenants selected from the waiting list files tested, 6 files contained the errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, 2022-004, and 2023-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are removed from the waiting list timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 005 – PIC Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances Finding 3 The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 3 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special reporting requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005 and 2023-005. Recommendation: We recommend that the Authority designate an individual to ensure the HUD- 50058s are uploaded into the PIC system accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 005 – PIC Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances Finding 3 The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 3 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special reporting requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005 and 2023-005. Recommendation: We recommend that the Authority designate an individual to ensure the HUD- 50058s are uploaded into the PIC system accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 005 – PIC Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances Finding 3 The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 3 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special reporting requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005 and 2023-005. Recommendation: We recommend that the Authority designate an individual to ensure the HUD- 50058s are uploaded into the PIC system accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 006 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). 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 960.259). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). (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 sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259). (4) Select tenants from the public housing waiting list (see III.N.2, “Special Tests and Provisions - Public Housing Waiting List”) (24 CFR sections 960.206 and 960.208). (5) 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: During the testing of the Public Housing Program tenant files, a compliance deficiency was noted: Of the 60 tenant files provided, auditor noted the following items: Number of Instances 1 Finding: Tenant income was improperly excluded from the HUD-50058 Questioned Costs: $12,630 Context: Out of 10 public housing tenant files tested, 1 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their ACOP. Effect: The Authority is not in compliance with federal regulations regarding reporting a tenant’s income in the HUD-50058. Repeat Finding: Yes, 2023-006. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 007 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Opportunities for Persons with Aids Assistance Listing Numbers: 14.241 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person’s family, including persons important to their care or well-being, as defined in 24 CFR section 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: During the testing of the HOPWA files, certain eligibility deficiencies were noted as summarized below: Number of Instances Finding 1 There was no support for excluding the income of a full-time college student for the recertification date tested 1 The annual inspection was not performed within a year. Questioned Costs: Undeterminable Context: Out of 29 HOPWA tenant files tested, 2 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their tenant files to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority is not in compliance with federal regulations regarding the verification of the tenants income and maintaining adequate documents per the compliance requirements. Repeat Finding: No. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 001 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). 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) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 4 The file is missing support for the calculation of HAP. Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 18 The EIV was missing from the file. 3 The file was missing the HUD-9886 authorization form. 3 The file was missing the Authority’s general release form. 12 The Authority did not review the tenant’s information on an annual basis 5 The allowable expenditures included in the file were not included on the 50058 9 The HAP paid was understated 2 The HAP income information reported in the 50058 did not agree to support. Questioned Costs: $12,428 Context: Out of 60 housing voucher cluster tenant files tested, 32 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, 2022-001, and 2023-001. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Conduct training for program staff on eligibility documentation requirements and program rules. 2. Initiate internal audits of tenant files to identify and correct documentation issues proactively. 3. Establish a monitoring protocol to ensure continued compliance and to prevent recurrence of documentation issues. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 001 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). 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) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 4 The file is missing support for the calculation of HAP. Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 18 The EIV was missing from the file. 3 The file was missing the HUD-9886 authorization form. 3 The file was missing the Authority’s general release form. 12 The Authority did not review the tenant’s information on an annual basis 5 The allowable expenditures included in the file were not included on the 50058 9 The HAP paid was understated 2 The HAP income information reported in the 50058 did not agree to support. Questioned Costs: $12,428 Context: Out of 60 housing voucher cluster tenant files tested, 32 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, 2022-001, and 2023-001. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Conduct training for program staff on eligibility documentation requirements and program rules. 2. Initiate internal audits of tenant files to identify and correct documentation issues proactively. 3. Establish a monitoring protocol to ensure continued compliance and to prevent recurrence of documentation issues. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 001 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). 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) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) 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). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 4 The file is missing support for the calculation of HAP. Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 18 The EIV was missing from the file. 3 The file was missing the HUD-9886 authorization form. 3 The file was missing the Authority’s general release form. 12 The Authority did not review the tenant’s information on an annual basis 5 The allowable expenditures included in the file were not included on the 50058 9 The HAP paid was understated 2 The HAP income information reported in the 50058 did not agree to support. Questioned Costs: $12,428 Context: Out of 60 housing voucher cluster tenant files tested, 32 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, 2022-001, and 2023-001. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Conduct training for program staff on eligibility documentation requirements and program rules. 2. Initiate internal audits of tenant files to identify and correct documentation issues proactively. 3. Establish a monitoring protocol to ensure continued compliance and to prevent recurrence of documentation issues. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 002 – Annual HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters Criteria or Specific Requirement: The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During the testing of 60 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Annual HQS Inspections Number of Instances Finding 2 The HQS inspection was not performed in a timely manner Questioned Costs: Undeterminable Context: Out of 60 files tested for annual inspections, 2 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, 2022-002, and 2023-002. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Implement a centralized tracking system to monitor inspection due dates and follow-up timelines to ensure all inspections are completed within the HUD-mandated timeframes. 2. Evaluate staffing levels and consider hiring additional inspectors or contracting third-party services to meet inspection demands. 3. Provide ongoing training on HQS protocols and compliance expectations. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 002 – Annual HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters Criteria or Specific Requirement: The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During the testing of 60 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Annual HQS Inspections Number of Instances Finding 2 The HQS inspection was not performed in a timely manner Questioned Costs: Undeterminable Context: Out of 60 files tested for annual inspections, 2 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, 2022-002, and 2023-002. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Implement a centralized tracking system to monitor inspection due dates and follow-up timelines to ensure all inspections are completed within the HUD-mandated timeframes. 2. Evaluate staffing levels and consider hiring additional inspectors or contracting third-party services to meet inspection demands. 3. Provide ongoing training on HQS protocols and compliance expectations. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 002 – Annual HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters Criteria or Specific Requirement: The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: During the testing of 60 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Annual HQS Inspections Number of Instances Finding 2 The HQS inspection was not performed in a timely manner Questioned Costs: Undeterminable Context: Out of 60 files tested for annual inspections, 2 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, 2022-002, and 2023-002. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Implement a centralized tracking system to monitor inspection due dates and follow-up timelines to ensure all inspections are completed within the HUD-mandated timeframes. 2. Evaluate staffing levels and consider hiring additional inspectors or contracting third-party services to meet inspection demands. 3. Provide ongoing training on HQS protocols and compliance expectations. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 003 – Rent Reasonableness Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance,Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA 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 a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of 80 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 1 The rent reasonableness was not performed prior to the effective date. Questioned Costs: Undeterminable Context: During our testing, we reviewed 80 tenant files that required rent reasonableness determinations; 1 tenant file contained errors as noted above. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unreasonable rent to the landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, 2022-003, and 2023-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 003 – Rent Reasonableness Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance,Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA 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 a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of 80 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 1 The rent reasonableness was not performed prior to the effective date. Questioned Costs: Undeterminable Context: During our testing, we reviewed 80 tenant files that required rent reasonableness determinations; 1 tenant file contained errors as noted above. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unreasonable rent to the landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, 2022-003, and 2023-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 003 – Rent Reasonableness Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance,Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA 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 a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During the testing of 80 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 1 The rent reasonableness was not performed prior to the effective date. Questioned Costs: Undeterminable Context: During our testing, we reviewed 80 tenant files that required rent reasonableness determinations; 1 tenant file contained errors as noted above. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unreasonable rent to the landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, 2022-003, and 2023-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 004 – Selection from the Waiting List Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (nonwaiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Tenant Selected from the Waiting List Number of Instances Finding 6 The tenant was not removed from the waitlist in accordance with policy. Questioned Costs: Undeterminable Context: Out of 60 tenants selected from the waiting list files tested, 6 files contained the errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, 2022-004, and 2023-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are removed from the waiting list timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 004 – Selection from the Waiting List Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (nonwaiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Tenant Selected from the Waiting List Number of Instances Finding 6 The tenant was not removed from the waitlist in accordance with policy. Questioned Costs: Undeterminable Context: Out of 60 tenants selected from the waiting list files tested, 6 files contained the errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, 2022-004, and 2023-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are removed from the waiting list timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 004 – Selection from the Waiting List Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (nonwaiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Tenant Selected from the Waiting List Number of Instances Finding 6 The tenant was not removed from the waitlist in accordance with policy. Questioned Costs: Undeterminable Context: Out of 60 tenants selected from the waiting list files tested, 6 files contained the errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, 2022-004, and 2023-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are removed from the waiting list timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 005 – PIC Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances Finding 3 The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 3 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special reporting requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005 and 2023-005. Recommendation: We recommend that the Authority designate an individual to ensure the HUD- 50058s are uploaded into the PIC system accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 005 – PIC Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances Finding 3 The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 3 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special reporting requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005 and 2023-005. Recommendation: We recommend that the Authority designate an individual to ensure the HUD- 50058s are uploaded into the PIC system accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 005 – PIC Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances Finding 3 The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 3 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special reporting requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005 and 2023-005. Recommendation: We recommend that the Authority designate an individual to ensure the HUD- 50058s are uploaded into the PIC system accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 006 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). 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 960.259). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). (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 sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259). (4) Select tenants from the public housing waiting list (see III.N.2, “Special Tests and Provisions - Public Housing Waiting List”) (24 CFR sections 960.206 and 960.208). (5) 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: During the testing of the Public Housing Program tenant files, a compliance deficiency was noted: Of the 60 tenant files provided, auditor noted the following items: Number of Instances 1 Finding: Tenant income was improperly excluded from the HUD-50058 Questioned Costs: $12,630 Context: Out of 10 public housing tenant files tested, 1 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their ACOP. Effect: The Authority is not in compliance with federal regulations regarding reporting a tenant’s income in the HUD-50058. Repeat Finding: Yes, 2023-006. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 007 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Opportunities for Persons with Aids Assistance Listing Numbers: 14.241 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person’s family, including persons important to their care or well-being, as defined in 24 CFR section 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: During the testing of the HOPWA files, certain eligibility deficiencies were noted as summarized below: Number of Instances Finding 1 There was no support for excluding the income of a full-time college student for the recertification date tested 1 The annual inspection was not performed within a year. Questioned Costs: Undeterminable Context: Out of 29 HOPWA tenant files tested, 2 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their tenant files to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority is not in compliance with federal regulations regarding the verification of the tenants income and maintaining adequate documents per the compliance requirements. Repeat Finding: No. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.