Audit 364184

Rent Reasonableness Finding Number: 2023-002 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions, Reasonable Rent Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-008 Noncompliance and Material Weakness 24 CFR § 982.158(f)(7) provides that the Public Housing Authority (PHA) must keep records to document the basis for PHA determination that rent to owner is a reasonable rent (initially and during the term of a HAP contract) for at least three years. 24 CFR § 982.54(d)(15) provide the Public Housing Authority (PHA) administrative plan must cover policies on the method of determining that rent to owner is a reasonable rent (initially and during the term of a Housing Assistance Payment contract). The Authority’s Housing Choice Voucher Administrative Plan Section 8 provides the Authority will make a rent reasonableness determination at initial occupancy and whenever the owner requests a rent adjustment. The Authority could not provide the reasonable rent certification for 12.5 percent of the initial occupancy tenant files tested and 1.7 percent of the current files tested for the Housing Voucher Cluster program. The failure to document rent reasonableness could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Housing and Urban Development. The Executive Director and Housing Voucher Cluster employees should ensure all tenant files maintain the appropriate documentation and meet the requirements for rent reasonableness.

Rent Reasonableness Finding Number: 2023-002 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions, Reasonable Rent Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-008 Noncompliance and Material Weakness 24 CFR § 982.158(f)(7) provides that the Public Housing Authority (PHA) must keep records to document the basis for PHA determination that rent to owner is a reasonable rent (initially and during the term of a HAP contract) for at least three years. 24 CFR § 982.54(d)(15) provide the Public Housing Authority (PHA) administrative plan must cover policies on the method of determining that rent to owner is a reasonable rent (initially and during the term of a Housing Assistance Payment contract). The Authority’s Housing Choice Voucher Administrative Plan Section 8 provides the Authority will make a rent reasonableness determination at initial occupancy and whenever the owner requests a rent adjustment. The Authority could not provide the reasonable rent certification for 12.5 percent of the initial occupancy tenant files tested and 1.7 percent of the current files tested for the Housing Voucher Cluster program. The failure to document rent reasonableness could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Housing and Urban Development. The Executive Director and Housing Voucher Cluster employees should ensure all tenant files maintain the appropriate documentation and meet the requirements for rent reasonableness.

HQS Enforcement Finding Number: 2023-003 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions, HQS Enforcement/Housing Quality Standards Inspections Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-004 Noncompliance and Material Weakness 2 CFR § 982.404 provides that the owner must maintain the unit in accordance with HQS. If the owner fails to maintain the dwelling unit in accordance with Housing Quality Standards (HQS), the PHA must take prompt and vigorous action to enforce the owner obligations. PHA remedies for such breach of the HQS include termination, suspension or reduction of housing assistance payments and termination of the HAP contract. The PHA must not make any housing assistance payments for a dwelling unit that fails to meet the HQS, unless the owner corrects the defect within the period specified by the PHA and the PHA verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). The owner is not responsible for a breach of the HQS that is not caused by the owner, and for which the family is responsible (as provided in § 982.404(b) and § 982.551(c)). However, the PHA may terminate assistance to a family because of HQS breach caused by the family. The Authority did not have HQS re-inspections completed within 30 calendar days for HQS inspection failures for 43 percent of inspection failures tested. Further, the Authority did not formally approve any related extensions. Failure to complete timely reinspections or approve extensions could result in dwellings not maintained in accordance with HQS. The Authority should complete re-inspections within the required time frame or approve extensions.

HQS Enforcement Finding Number: 2023-003 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions, HQS Enforcement/Housing Quality Standards Inspections Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-004 Noncompliance and Material Weakness 2 CFR § 982.404 provides that the owner must maintain the unit in accordance with HQS. If the owner fails to maintain the dwelling unit in accordance with Housing Quality Standards (HQS), the PHA must take prompt and vigorous action to enforce the owner obligations. PHA remedies for such breach of the HQS include termination, suspension or reduction of housing assistance payments and termination of the HAP contract. The PHA must not make any housing assistance payments for a dwelling unit that fails to meet the HQS, unless the owner corrects the defect within the period specified by the PHA and the PHA verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). The owner is not responsible for a breach of the HQS that is not caused by the owner, and for which the family is responsible (as provided in § 982.404(b) and § 982.551(c)). However, the PHA may terminate assistance to a family because of HQS breach caused by the family. The Authority did not have HQS re-inspections completed within 30 calendar days for HQS inspection failures for 43 percent of inspection failures tested. Further, the Authority did not formally approve any related extensions. Failure to complete timely reinspections or approve extensions could result in dwellings not maintained in accordance with HQS. The Authority should complete re-inspections within the required time frame or approve extensions.

Reporting Finding Number: 2023-004 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Reporting Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-005 Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.328 which provides that, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB approved common information collections, as applicable, when providing financial and performance reporting information. 24 CFR § 5.801 (d)(1) provides that unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F. In addition, 24 CFR § 5.801 (b)(1) provides that entities to which this subpart is applicable must provide to HUD such financial information as required by HUD prepared in accordance with Generally Accepted Accounting Principles (GAAP). The Authority submitted its audited submission for the year ended December 31, 2022 in the Financial Assessment Sub-system (FASS-PH) on October 30, 2024. The Authority had received a ninety-two-day extension until December 31, 2023. This submission was not within the required timeframes or extension. The delays in submissions were due to investigations into fraudulent transactions by the former Executive Director. The failure to timely submit the required financial information reduces the U.S. Department of Housing and Urban Development’s ability to monitor subrecipients. The Authority should continue working with their compiler and auditors to rectify the accounting issues resulting from the actions of the former Executive Director. Once that is completed, the Authority should timely remit the required reports.

Reporting Finding Number: 2023-004 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Reporting Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-005 Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.328 which provides that, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB approved common information collections, as applicable, when providing financial and performance reporting information. 24 CFR § 5.801 (d)(1) provides that unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F. In addition, 24 CFR § 5.801 (b)(1) provides that entities to which this subpart is applicable must provide to HUD such financial information as required by HUD prepared in accordance with Generally Accepted Accounting Principles (GAAP). The Authority submitted its audited submission for the year ended December 31, 2022 in the Financial Assessment Sub-system (FASS-PH) on October 30, 2024. The Authority had received a ninety-two-day extension until December 31, 2023. This submission was not within the required timeframes or extension. The delays in submissions were due to investigations into fraudulent transactions by the former Executive Director. The failure to timely submit the required financial information reduces the U.S. Department of Housing and Urban Development’s ability to monitor subrecipients. The Authority should continue working with their compiler and auditors to rectify the accounting issues resulting from the actions of the former Executive Director. Once that is completed, the Authority should timely remit the required reports.

Payroll Allocations and Contract Allocations Finding Number: 2023-005 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-007 Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR Part 200 Subpart E § 200.403 which provides that, except where otherwise authorized by statute, costs must meet certain general criteria in order to be allowable under Federal awards including being necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and being adequately documented. 2 C.F.R. § 200.430 provides, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. The Authority utilizes a standard allocation of 85% to serve as a cost allocation plan for consultant contracts to the Housing Choice Voucher (HCV) Program. However, the percentages in the plan are not updated annually and the plan does not specify which expenses are subject to the allocation percentage. Further, the Authority was unable to provide supporting documentation for the allocation percentages in the plan. As such, during 2023, the Authority charged $9,068 to the Housing Voucher Cluster in excess of supported amounts. In addition, the Authority approved a standard allocation of 59% for employee benefits charged to the Housing Choice Voucher (HCV) Program. However, the Authority charged 85% of certain benefits for employees during 2023 resulting in $2,080 charged to the Housing Voucher Cluster in excess of supported amounts. The failure to update and support percentages used to allocate federal expenditures to ensure they are reasonable based on current activity could result in findings for adjustment or questioned costs in the federal programs. During 2023, the total unsupported charges totaled $11,148. The Authority should update the percentages used in its cost allocation plan. Further, the Authority should update its plan to identify which expenses are subject to allocation by this plan. In addition, the Authority should utilize only approved and supported percentages for allocation of federal expenditures.

Payroll Allocations and Contract Allocations Finding Number: 2023-005 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-007 Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR Part 200 Subpart E § 200.403 which provides that, except where otherwise authorized by statute, costs must meet certain general criteria in order to be allowable under Federal awards including being necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and being adequately documented. 2 C.F.R. § 200.430 provides, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. The Authority utilizes a standard allocation of 85% to serve as a cost allocation plan for consultant contracts to the Housing Choice Voucher (HCV) Program. However, the percentages in the plan are not updated annually and the plan does not specify which expenses are subject to the allocation percentage. Further, the Authority was unable to provide supporting documentation for the allocation percentages in the plan. As such, during 2023, the Authority charged $9,068 to the Housing Voucher Cluster in excess of supported amounts. In addition, the Authority approved a standard allocation of 59% for employee benefits charged to the Housing Choice Voucher (HCV) Program. However, the Authority charged 85% of certain benefits for employees during 2023 resulting in $2,080 charged to the Housing Voucher Cluster in excess of supported amounts. The failure to update and support percentages used to allocate federal expenditures to ensure they are reasonable based on current activity could result in findings for adjustment or questioned costs in the federal programs. During 2023, the total unsupported charges totaled $11,148. The Authority should update the percentages used in its cost allocation plan. Further, the Authority should update its plan to identify which expenses are subject to allocation by this plan. In addition, the Authority should utilize only approved and supported percentages for allocation of federal expenditures.

Rent Reasonableness Finding Number: 2023-002 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions, Reasonable Rent Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-008 Noncompliance and Material Weakness 24 CFR § 982.158(f)(7) provides that the Public Housing Authority (PHA) must keep records to document the basis for PHA determination that rent to owner is a reasonable rent (initially and during the term of a HAP contract) for at least three years. 24 CFR § 982.54(d)(15) provide the Public Housing Authority (PHA) administrative plan must cover policies on the method of determining that rent to owner is a reasonable rent (initially and during the term of a Housing Assistance Payment contract). The Authority’s Housing Choice Voucher Administrative Plan Section 8 provides the Authority will make a rent reasonableness determination at initial occupancy and whenever the owner requests a rent adjustment. The Authority could not provide the reasonable rent certification for 12.5 percent of the initial occupancy tenant files tested and 1.7 percent of the current files tested for the Housing Voucher Cluster program. The failure to document rent reasonableness could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Housing and Urban Development. The Executive Director and Housing Voucher Cluster employees should ensure all tenant files maintain the appropriate documentation and meet the requirements for rent reasonableness.

Rent Reasonableness Finding Number: 2023-002 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions, Reasonable Rent Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-008 Noncompliance and Material Weakness 24 CFR § 982.158(f)(7) provides that the Public Housing Authority (PHA) must keep records to document the basis for PHA determination that rent to owner is a reasonable rent (initially and during the term of a HAP contract) for at least three years. 24 CFR § 982.54(d)(15) provide the Public Housing Authority (PHA) administrative plan must cover policies on the method of determining that rent to owner is a reasonable rent (initially and during the term of a Housing Assistance Payment contract). The Authority’s Housing Choice Voucher Administrative Plan Section 8 provides the Authority will make a rent reasonableness determination at initial occupancy and whenever the owner requests a rent adjustment. The Authority could not provide the reasonable rent certification for 12.5 percent of the initial occupancy tenant files tested and 1.7 percent of the current files tested for the Housing Voucher Cluster program. The failure to document rent reasonableness could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Housing and Urban Development. The Executive Director and Housing Voucher Cluster employees should ensure all tenant files maintain the appropriate documentation and meet the requirements for rent reasonableness.

HQS Enforcement Finding Number: 2023-003 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions, HQS Enforcement/Housing Quality Standards Inspections Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-004 Noncompliance and Material Weakness 2 CFR § 982.404 provides that the owner must maintain the unit in accordance with HQS. If the owner fails to maintain the dwelling unit in accordance with Housing Quality Standards (HQS), the PHA must take prompt and vigorous action to enforce the owner obligations. PHA remedies for such breach of the HQS include termination, suspension or reduction of housing assistance payments and termination of the HAP contract. The PHA must not make any housing assistance payments for a dwelling unit that fails to meet the HQS, unless the owner corrects the defect within the period specified by the PHA and the PHA verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). The owner is not responsible for a breach of the HQS that is not caused by the owner, and for which the family is responsible (as provided in § 982.404(b) and § 982.551(c)). However, the PHA may terminate assistance to a family because of HQS breach caused by the family. The Authority did not have HQS re-inspections completed within 30 calendar days for HQS inspection failures for 43 percent of inspection failures tested. Further, the Authority did not formally approve any related extensions. Failure to complete timely reinspections or approve extensions could result in dwellings not maintained in accordance with HQS. The Authority should complete re-inspections within the required time frame or approve extensions.

HQS Enforcement Finding Number: 2023-003 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions, HQS Enforcement/Housing Quality Standards Inspections Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-004 Noncompliance and Material Weakness 2 CFR § 982.404 provides that the owner must maintain the unit in accordance with HQS. If the owner fails to maintain the dwelling unit in accordance with Housing Quality Standards (HQS), the PHA must take prompt and vigorous action to enforce the owner obligations. PHA remedies for such breach of the HQS include termination, suspension or reduction of housing assistance payments and termination of the HAP contract. The PHA must not make any housing assistance payments for a dwelling unit that fails to meet the HQS, unless the owner corrects the defect within the period specified by the PHA and the PHA verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension). The owner is not responsible for a breach of the HQS that is not caused by the owner, and for which the family is responsible (as provided in § 982.404(b) and § 982.551(c)). However, the PHA may terminate assistance to a family because of HQS breach caused by the family. The Authority did not have HQS re-inspections completed within 30 calendar days for HQS inspection failures for 43 percent of inspection failures tested. Further, the Authority did not formally approve any related extensions. Failure to complete timely reinspections or approve extensions could result in dwellings not maintained in accordance with HQS. The Authority should complete re-inspections within the required time frame or approve extensions.

Reporting Finding Number: 2023-004 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Reporting Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-005 Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.328 which provides that, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB approved common information collections, as applicable, when providing financial and performance reporting information. 24 CFR § 5.801 (d)(1) provides that unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F. In addition, 24 CFR § 5.801 (b)(1) provides that entities to which this subpart is applicable must provide to HUD such financial information as required by HUD prepared in accordance with Generally Accepted Accounting Principles (GAAP). The Authority submitted its audited submission for the year ended December 31, 2022 in the Financial Assessment Sub-system (FASS-PH) on October 30, 2024. The Authority had received a ninety-two-day extension until December 31, 2023. This submission was not within the required timeframes or extension. The delays in submissions were due to investigations into fraudulent transactions by the former Executive Director. The failure to timely submit the required financial information reduces the U.S. Department of Housing and Urban Development’s ability to monitor subrecipients. The Authority should continue working with their compiler and auditors to rectify the accounting issues resulting from the actions of the former Executive Director. Once that is completed, the Authority should timely remit the required reports.

Reporting Finding Number: 2023-004 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Reporting Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-005 Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.328 which provides that, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB approved common information collections, as applicable, when providing financial and performance reporting information. 24 CFR § 5.801 (d)(1) provides that unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F. In addition, 24 CFR § 5.801 (b)(1) provides that entities to which this subpart is applicable must provide to HUD such financial information as required by HUD prepared in accordance with Generally Accepted Accounting Principles (GAAP). The Authority submitted its audited submission for the year ended December 31, 2022 in the Financial Assessment Sub-system (FASS-PH) on October 30, 2024. The Authority had received a ninety-two-day extension until December 31, 2023. This submission was not within the required timeframes or extension. The delays in submissions were due to investigations into fraudulent transactions by the former Executive Director. The failure to timely submit the required financial information reduces the U.S. Department of Housing and Urban Development’s ability to monitor subrecipients. The Authority should continue working with their compiler and auditors to rectify the accounting issues resulting from the actions of the former Executive Director. Once that is completed, the Authority should timely remit the required reports.

Payroll Allocations and Contract Allocations Finding Number: 2023-005 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-007 Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR Part 200 Subpart E § 200.403 which provides that, except where otherwise authorized by statute, costs must meet certain general criteria in order to be allowable under Federal awards including being necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and being adequately documented. 2 C.F.R. § 200.430 provides, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. The Authority utilizes a standard allocation of 85% to serve as a cost allocation plan for consultant contracts to the Housing Choice Voucher (HCV) Program. However, the percentages in the plan are not updated annually and the plan does not specify which expenses are subject to the allocation percentage. Further, the Authority was unable to provide supporting documentation for the allocation percentages in the plan. As such, during 2023, the Authority charged $9,068 to the Housing Voucher Cluster in excess of supported amounts. In addition, the Authority approved a standard allocation of 59% for employee benefits charged to the Housing Choice Voucher (HCV) Program. However, the Authority charged 85% of certain benefits for employees during 2023 resulting in $2,080 charged to the Housing Voucher Cluster in excess of supported amounts. The failure to update and support percentages used to allocate federal expenditures to ensure they are reasonable based on current activity could result in findings for adjustment or questioned costs in the federal programs. During 2023, the total unsupported charges totaled $11,148. The Authority should update the percentages used in its cost allocation plan. Further, the Authority should update its plan to identify which expenses are subject to allocation by this plan. In addition, the Authority should utilize only approved and supported percentages for allocation of federal expenditures.

Payroll Allocations and Contract Allocations Finding Number: 2023-005 Assistance Listing Number and Title: AL # 14.871 - Section 8 Housing Choice Vouchers/Housing Voucher Cluster Federal Award Identification Number / Year: 2023 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Pass-Through Entity: N/A Repeat Finding from Prior Audit? Yes Prior Audit Finding Number: 2022-007 Noncompliance and Material Weakness 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR Part 200 Subpart E § 200.403 which provides that, except where otherwise authorized by statute, costs must meet certain general criteria in order to be allowable under Federal awards including being necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and being adequately documented. 2 C.F.R. § 200.430 provides, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. The Authority utilizes a standard allocation of 85% to serve as a cost allocation plan for consultant contracts to the Housing Choice Voucher (HCV) Program. However, the percentages in the plan are not updated annually and the plan does not specify which expenses are subject to the allocation percentage. Further, the Authority was unable to provide supporting documentation for the allocation percentages in the plan. As such, during 2023, the Authority charged $9,068 to the Housing Voucher Cluster in excess of supported amounts. In addition, the Authority approved a standard allocation of 59% for employee benefits charged to the Housing Choice Voucher (HCV) Program. However, the Authority charged 85% of certain benefits for employees during 2023 resulting in $2,080 charged to the Housing Voucher Cluster in excess of supported amounts. The failure to update and support percentages used to allocate federal expenditures to ensure they are reasonable based on current activity could result in findings for adjustment or questioned costs in the federal programs. During 2023, the total unsupported charges totaled $11,148. The Authority should update the percentages used in its cost allocation plan. Further, the Authority should update its plan to identify which expenses are subject to allocation by this plan. In addition, the Authority should utilize only approved and supported percentages for allocation of federal expenditures.