Audit 364319

Criteria - In accordance with 24 CFR §905.306(d)(5) and HUD Capital Fund Program (CFP) (Assistance Listing 14.872) requirements, a Public Housing Authority must obligate at least 90 percent of each Capital Fund grant, including formula grants, non-accumulating Replacement Housing Factor (RHF) funds, natural disaster funds, and lead-based paint grants, within 24 months of the funds becoming available for obligation. Condition - The Authority did not obligate at least 90 percent of its 2021 and 2022 CFP grants (MA01P099501-21 and MA01P099501-22) within the required 24-month period. As of the obligation end date, the Authority remained below the 90 percent obligation threshold for both grants. Cause - The Authority did not implement timely project planning, contract execution, or expenditure processes necessary to ensure compliance with the Capital Fund obligation requirements. Additionally, the Authority had executive level turnover. Effect - As a result of noncompliance, all of the Authority’s Capital Fund Program grants have been suspended. The Authority is unable to draw funds from the HUD Line of Credit Control System (LOCCS), which may delay or halt the execution of essential capital improvements and negatively impact the Authority’s residents. Questioned Costs - None reported. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Recommendation - We recommend the Authority develop and implement corrective action plans to ensure timely obligation of CFP grants in accordance with HUD requirements. The Authority should also conduct regular monitoring of grant obligation status and establish internal controls to prevent future noncompliance. Lastly, the Authority should communicate with HUD to determine any possible remedies or waivers and to seek guidance on reinstatement of suspended funds. Managements 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 work with HUD to reinstate the CFP grants and ensure all future deadlines are met. (c) Planned implementation date of corrective action - Completed by August 31, 2025.

Criteria - In accordance with 24 CFR §905.306(d)(5) and HUD Capital Fund Program (CFP) (Assistance Listing 14.872) requirements, a Public Housing Authority must obligate at least 90 percent of each Capital Fund grant, including formula grants, non-accumulating Replacement Housing Factor (RHF) funds, natural disaster funds, and lead-based paint grants, within 24 months of the funds becoming available for obligation. Condition - The Authority did not obligate at least 90 percent of its 2021 and 2022 CFP grants (MA01P099501-21 and MA01P099501-22) within the required 24-month period. As of the obligation end date, the Authority remained below the 90 percent obligation threshold for both grants. Cause - The Authority did not implement timely project planning, contract execution, or expenditure processes necessary to ensure compliance with the Capital Fund obligation requirements. Additionally, the Authority had executive level turnover. Effect - As a result of noncompliance, all of the Authority’s Capital Fund Program grants have been suspended. The Authority is unable to draw funds from the HUD Line of Credit Control System (LOCCS), which may delay or halt the execution of essential capital improvements and negatively impact the Authority’s residents. Questioned Costs - None reported. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Recommendation - We recommend the Authority develop and implement corrective action plans to ensure timely obligation of CFP grants in accordance with HUD requirements. The Authority should also conduct regular monitoring of grant obligation status and establish internal controls to prevent future noncompliance. Lastly, the Authority should communicate with HUD to determine any possible remedies or waivers and to seek guidance on reinstatement of suspended funds. Managements 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 work with HUD to reinstate the CFP grants and ensure all future deadlines are met. (c) Planned implementation date of corrective action - Completed by August 31, 2025.