Criteria - Uniform Guidance (2 CFR §200.303) requires recipients of federal awards to establish and maintain effective internal controls over compliance. Specifically, 24 CFR §982.201 and related program requirements for the Housing Choice Voucher Program (HCV) (Assistance Listing Number 14.871) mandate:
1) Documentation of eligibility (including citizenship/immigration status and income verification).
2) Signed lease agreements between the tenant and owner.
3) Rent reasonableness determinations for all units.
4) Housing Quality Standards (HQS) inspections must be documented prior to lease-up and annually thereafter.
5) Recertifications (HUD-50058) and authorizations to release information (HUD-9886) must be on file.
Condition - During testing of 40 participant files, we were unable to verify compliance with key program requirements due to missing documentation as detailed below:
Deficiency Number of Files Affected
Missing signed application 19 out of 40
Missing signed lease agreement 29 out of 40
Missing proof of citizenship/eligible immigration status 20 out of 40
Missing documentation of independent income verification 11 out of 40
Missing HUD-50058 recertification 11 out of 40
Missing HUD-9886 (Authorization for Release of Information) 14 out of 40
Missing documentation of rent reasonableness 18 out of 40
Missing HQS inspection documentation 25 out of 40
Cause - The Authority did not maintain adequate documentation in participant files, indicating a lack of effective internal controls over file management and compliance monitoring.
Effect - The absence of required documentation increases the risk of non-compliance with HUD regulations, which may result in findings during HUD reviews or audits and possible loss of HUD funding or sanctions if deficiencies are not corrected.
Questioned Costs - Due to missing documentation, the allowability of housing assistance payments for the impacted participants cannot be determined.
Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample.
Recommendation - To address the deficiencies identified in the HCV Program tenant files, we recommend that the Authority implement comprehensive measures to strengthen compliance and improve internal controls. First, the Authority should conduct a full review of all tenant files to identify and resolve missing documentation, using a standardized checklist to ensure all required documents are included in each file.
Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken.
(b) Action taken - The Authority will conduct a thorough review of all tenant files to identify and resolve missing documentation, including signed applications, lease agreements, proof of citizenship or eligible immigration status, independent income verification, HUD forms (50058 and 9886), rent reasonableness documentation, and HQS inspection records. Staff will work to obtain missing documents from tenants, landlords, or other necessary parties. A standardized checklist should be used to ensure all required items are present in each file moving forward.
(c) Planned implementation date of corrective action - Completed by September 30, 2025.
Criteria - Per Capital Fund Program (CFP) (Assisting Listing Number 14.872) regulations (24 CFR 905.322), a Public Housing Authority is required to submit form HUD-53001, Actual Modernization Cost Certificate (AMCC) within 90 days after the expenditure end date of the grant, in order to initiate the closeout process. The AMCC must detail actual costs incurred from the Date of Full Availability (DOFA) to the completion of the modernization project.
Condition - The Authority received a CFP grant (Grant No. NY01P035501-18) with an expenditure end date of May 28, 2024. The final draw on this grant was made on December 22, 2022. As of the date of this independent auditors’ report, the Authority has not submitted the AMCC to HUD Actual Modernization Cost Certificate (AMCC) to the HUD within the required timeframe.
Cause - The failure to complete the AMCC and closeout process appears to stem from administrative oversight and a lack of monitoring controls to ensure compliance with HUD’s grant requirements.
Effect - Failure to timely submit the AMCC may is not compliant with HUD regulations, which may affect the Authority’s ability to secure future funding allocations.
Questioned Costs - None identified.
Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample.
Recommendation - The Authority should expedite the completion of the AMCC and submit the necessary closeout documentation for NY01P035501-18 to HUD. Additionally, the Authority should develop and implement a grant management tracking system to monitor the status of all active grants, including deadlines for closeout and AMCC completion.
Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken.
(b) Action taken - The Authority will immediately initiate the closeout process for the two CFP grants by preparing and submitting all required closeout documentation to HUD. This includes completing the AMCC, certifying expenditures, and submitting necessary reports through HUD’s electronic systems, as outlined in the Capital Fund Guidebook.
(c) Planned implementation date of corrective action - Completed by September 30, 2025.
Criteria - Uniform Guidance (2 CFR §200.303) requires recipients of federal awards to establish and maintain effective internal controls over compliance. Specifically, 24 CFR §982.201 and related program requirements for the Housing Choice Voucher Program (HCV) (Assistance Listing Number 14.871) mandate:
1) Documentation of eligibility (including citizenship/immigration status and income verification).
2) Signed lease agreements between the tenant and owner.
3) Rent reasonableness determinations for all units.
4) Housing Quality Standards (HQS) inspections must be documented prior to lease-up and annually thereafter.
5) Recertifications (HUD-50058) and authorizations to release information (HUD-9886) must be on file.
Condition - During testing of 40 participant files, we were unable to verify compliance with key program requirements due to missing documentation as detailed below:
Deficiency Number of Files Affected
Missing signed application 19 out of 40
Missing signed lease agreement 29 out of 40
Missing proof of citizenship/eligible immigration status 20 out of 40
Missing documentation of independent income verification 11 out of 40
Missing HUD-50058 recertification 11 out of 40
Missing HUD-9886 (Authorization for Release of Information) 14 out of 40
Missing documentation of rent reasonableness 18 out of 40
Missing HQS inspection documentation 25 out of 40
Cause - The Authority did not maintain adequate documentation in participant files, indicating a lack of effective internal controls over file management and compliance monitoring.
Effect - The absence of required documentation increases the risk of non-compliance with HUD regulations, which may result in findings during HUD reviews or audits and possible loss of HUD funding or sanctions if deficiencies are not corrected.
Questioned Costs - Due to missing documentation, the allowability of housing assistance payments for the impacted participants cannot be determined.
Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample.
Recommendation - To address the deficiencies identified in the HCV Program tenant files, we recommend that the Authority implement comprehensive measures to strengthen compliance and improve internal controls. First, the Authority should conduct a full review of all tenant files to identify and resolve missing documentation, using a standardized checklist to ensure all required documents are included in each file.
Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken.
(b) Action taken - The Authority will conduct a thorough review of all tenant files to identify and resolve missing documentation, including signed applications, lease agreements, proof of citizenship or eligible immigration status, independent income verification, HUD forms (50058 and 9886), rent reasonableness documentation, and HQS inspection records. Staff will work to obtain missing documents from tenants, landlords, or other necessary parties. A standardized checklist should be used to ensure all required items are present in each file moving forward.
(c) Planned implementation date of corrective action - Completed by September 30, 2025.
Criteria - Per Capital Fund Program (CFP) (Assisting Listing Number 14.872) regulations (24 CFR 905.322), a Public Housing Authority is required to submit form HUD-53001, Actual Modernization Cost Certificate (AMCC) within 90 days after the expenditure end date of the grant, in order to initiate the closeout process. The AMCC must detail actual costs incurred from the Date of Full Availability (DOFA) to the completion of the modernization project.
Condition - The Authority received a CFP grant (Grant No. NY01P035501-18) with an expenditure end date of May 28, 2024. The final draw on this grant was made on December 22, 2022. As of the date of this independent auditors’ report, the Authority has not submitted the AMCC to HUD Actual Modernization Cost Certificate (AMCC) to the HUD within the required timeframe.
Cause - The failure to complete the AMCC and closeout process appears to stem from administrative oversight and a lack of monitoring controls to ensure compliance with HUD’s grant requirements.
Effect - Failure to timely submit the AMCC may is not compliant with HUD regulations, which may affect the Authority’s ability to secure future funding allocations.
Questioned Costs - None identified.
Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample.
Recommendation - The Authority should expedite the completion of the AMCC and submit the necessary closeout documentation for NY01P035501-18 to HUD. Additionally, the Authority should develop and implement a grant management tracking system to monitor the status of all active grants, including deadlines for closeout and AMCC completion.
Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken.
(b) Action taken - The Authority will immediately initiate the closeout process for the two CFP grants by preparing and submitting all required closeout documentation to HUD. This includes completing the AMCC, certifying expenditures, and submitting necessary reports through HUD’s electronic systems, as outlined in the Capital Fund Guidebook.
(c) Planned implementation date of corrective action - Completed by September 30, 2025.