Audit 365535

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reasonable Rent Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for HCVP program. "The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner." Condition: HALC was unable to provide the necessary documentation to support the following Housing Voucher Cluster compliance requirements: Special Tests: -Reasonable rent Context: During our testing over reasonable rent, auditor noted 1 of the 40 selections tested had no documentation that their determination of rent to owners is reasonable in accordance with their administrative plan at initial leasing and during the term of the contract as required. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that reasonable rent files are processed accordingly. Effect: The Authority is not in compliance with program requirements over reasonable rent. Recommendation: We recommend that the Authority implement internal controls to ensure tenant reasonable rent files are maintained with adequate documentation. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reporting PIC Assistance Listing Number: 14.871 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for the Moving To Work Program, "The information on [HUD-50058, Family Report] is submitted to HUD through the Inventory Management System/Public and Indian Housing Information Center (IMS/PIC). [...] Data must be submitted 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." Condition: The Authority did not have adequate internal controls designed to ensure that all HUD-50058s were properly uploaded to the PIC system. Special Tests: -PIC testing Context: During our testing over PIC, auditor noted 1 of the 40 selections tested had no updated HUD-50058 form in accordance with OMB Compliance Supplement criteria. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that PIC uploads were processed accordingly. Effect: The Authority is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months. The Authority is also not in compliance with its own administrative policy on the HCV program. Recommendation: We recommend that the Authority implement a higher-level review of the HUD-50058 listing that gets uploaded to the PIC system. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: (1) According to the Authority's internal procedures, case managers are to complete a checklist to keep in tenant file any time a new computation is created, be that for an annual, interim, or special reexamination. This must be signed and dated by the completing caseworker. (2) According to the compliance supplement for the Housing Voucher Cluster, "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). 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). Condition: The Authority did not have adequate internal controls designed to ensure that all proper documentation was signed. Special Tests: -Eligibility Context: During our testing over eligibility, auditor noted 3 of the 40 selections tested had missing signed documentation that the Authority had to have the tenant sign in accordance with the Authority’s internal procedures and compliance supplement for Housing Voucher Cluster program. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure it is meeting eligibility requirements set by HUD. Effect: The Authority is not in compliance with program requirements over eligibility. Recommendation: We recommend the Authority implement processes to ensure that all proper documentation is being maintained during the process for every tenant. Views of Responsible Officials: There is no disagreement with the audit finding.

HCVP Depository Agreement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Federal Award Identification Number and Year: OR005 – 2024 Assistance Listing Number: 14.871 / 14.879 Award Period: January 1, 2024 through December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD. The agreements serve as safeguards for federal funds and provide third-party rights to HUD. Among the terms in many agreements are requirements for funds to be placed in an interest-bearing account (24 CFR section 982.156). Condition: The Authority did not have adequate internal controls designed to ensure that depository agreements are maintained for banks that hold HUD funds. Context: During our testing, we noted the Authority did not have a depository agreement with its’ financial institution in the form required by HUD funds. Questioned costs: None Cause: The Authority does not have controls in place to ensure it is meeting all requirements set by HUD. Effect: The Authority is not in compliance with program requirements. Recommendation: The Authority should obtain depository agreements for all bank accounts required by HUD. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reasonable Rent Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for HCVP program. "The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner." Condition: HALC was unable to provide the necessary documentation to support the following Housing Voucher Cluster compliance requirements: Special Tests: -Reasonable rent Context: During our testing over reasonable rent, auditor noted 1 of the 40 selections tested had no documentation that their determination of rent to owners is reasonable in accordance with their administrative plan at initial leasing and during the term of the contract as required. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that reasonable rent files are processed accordingly. Effect: The Authority is not in compliance with program requirements over reasonable rent. Recommendation: We recommend that the Authority implement internal controls to ensure tenant reasonable rent files are maintained with adequate documentation. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reporting PIC Assistance Listing Number: 14.871 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for the Moving To Work Program, "The information on [HUD-50058, Family Report] is submitted to HUD through the Inventory Management System/Public and Indian Housing Information Center (IMS/PIC). [...] Data must be submitted 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." Condition: The Authority did not have adequate internal controls designed to ensure that all HUD-50058s were properly uploaded to the PIC system. Special Tests: -PIC testing Context: During our testing over PIC, auditor noted 1 of the 40 selections tested had no updated HUD-50058 form in accordance with OMB Compliance Supplement criteria. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that PIC uploads were processed accordingly. Effect: The Authority is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months. The Authority is also not in compliance with its own administrative policy on the HCV program. Recommendation: We recommend that the Authority implement a higher-level review of the HUD-50058 listing that gets uploaded to the PIC system. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: (1) According to the Authority's internal procedures, case managers are to complete a checklist to keep in tenant file any time a new computation is created, be that for an annual, interim, or special reexamination. This must be signed and dated by the completing caseworker. (2) According to the compliance supplement for the Housing Voucher Cluster, "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). 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). Condition: The Authority did not have adequate internal controls designed to ensure that all proper documentation was signed. Special Tests: -Eligibility Context: During our testing over eligibility, auditor noted 3 of the 40 selections tested had missing signed documentation that the Authority had to have the tenant sign in accordance with the Authority’s internal procedures and compliance supplement for Housing Voucher Cluster program. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure it is meeting eligibility requirements set by HUD. Effect: The Authority is not in compliance with program requirements over eligibility. Recommendation: We recommend the Authority implement processes to ensure that all proper documentation is being maintained during the process for every tenant. Views of Responsible Officials: There is no disagreement with the audit finding.

HCVP Depository Agreement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Federal Award Identification Number and Year: OR005 – 2024 Assistance Listing Number: 14.871 / 14.879 Award Period: January 1, 2024 through December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD. The agreements serve as safeguards for federal funds and provide third-party rights to HUD. Among the terms in many agreements are requirements for funds to be placed in an interest-bearing account (24 CFR section 982.156). Condition: The Authority did not have adequate internal controls designed to ensure that depository agreements are maintained for banks that hold HUD funds. Context: During our testing, we noted the Authority did not have a depository agreement with its’ financial institution in the form required by HUD funds. Questioned costs: None Cause: The Authority does not have controls in place to ensure it is meeting all requirements set by HUD. Effect: The Authority is not in compliance with program requirements. Recommendation: The Authority should obtain depository agreements for all bank accounts required by HUD. View of Responsible Officials: There is no disagreement with the audit finding.

HCVP Depository Agreement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Federal Award Identification Number and Year: OR005 – 2024 Assistance Listing Number: 14.871 / 14.879 Award Period: January 1, 2024 through December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD. The agreements serve as safeguards for federal funds and provide third-party rights to HUD. Among the terms in many agreements are requirements for funds to be placed in an interest-bearing account (24 CFR section 982.156). Condition: The Authority did not have adequate internal controls designed to ensure that depository agreements are maintained for banks that hold HUD funds. Context: During our testing, we noted the Authority did not have a depository agreement with its’ financial institution in the form required by HUD funds. Questioned costs: None Cause: The Authority does not have controls in place to ensure it is meeting all requirements set by HUD. Effect: The Authority is not in compliance with program requirements. Recommendation: The Authority should obtain depository agreements for all bank accounts required by HUD. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reasonable Rent Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for HCVP program. "The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner." Condition: HALC was unable to provide the necessary documentation to support the following Housing Voucher Cluster compliance requirements: Special Tests: -Reasonable rent Context: During our testing over reasonable rent, auditor noted 1 of the 40 selections tested had no documentation that their determination of rent to owners is reasonable in accordance with their administrative plan at initial leasing and during the term of the contract as required. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that reasonable rent files are processed accordingly. Effect: The Authority is not in compliance with program requirements over reasonable rent. Recommendation: We recommend that the Authority implement internal controls to ensure tenant reasonable rent files are maintained with adequate documentation. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reporting PIC Assistance Listing Number: 14.871 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for the Moving To Work Program, "The information on [HUD-50058, Family Report] is submitted to HUD through the Inventory Management System/Public and Indian Housing Information Center (IMS/PIC). [...] Data must be submitted 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." Condition: The Authority did not have adequate internal controls designed to ensure that all HUD-50058s were properly uploaded to the PIC system. Special Tests: -PIC testing Context: During our testing over PIC, auditor noted 1 of the 40 selections tested had no updated HUD-50058 form in accordance with OMB Compliance Supplement criteria. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that PIC uploads were processed accordingly. Effect: The Authority is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months. The Authority is also not in compliance with its own administrative policy on the HCV program. Recommendation: We recommend that the Authority implement a higher-level review of the HUD-50058 listing that gets uploaded to the PIC system. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: (1) According to the Authority's internal procedures, case managers are to complete a checklist to keep in tenant file any time a new computation is created, be that for an annual, interim, or special reexamination. This must be signed and dated by the completing caseworker. (2) According to the compliance supplement for the Housing Voucher Cluster, "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). 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). Condition: The Authority did not have adequate internal controls designed to ensure that all proper documentation was signed. Special Tests: -Eligibility Context: During our testing over eligibility, auditor noted 3 of the 40 selections tested had missing signed documentation that the Authority had to have the tenant sign in accordance with the Authority’s internal procedures and compliance supplement for Housing Voucher Cluster program. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure it is meeting eligibility requirements set by HUD. Effect: The Authority is not in compliance with program requirements over eligibility. Recommendation: We recommend the Authority implement processes to ensure that all proper documentation is being maintained during the process for every tenant. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reasonable Rent Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for HCVP program. "The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner." Condition: HALC was unable to provide the necessary documentation to support the following Housing Voucher Cluster compliance requirements: Special Tests: -Reasonable rent Context: During our testing over reasonable rent, auditor noted 1 of the 40 selections tested had no documentation that their determination of rent to owners is reasonable in accordance with their administrative plan at initial leasing and during the term of the contract as required. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that reasonable rent files are processed accordingly. Effect: The Authority is not in compliance with program requirements over reasonable rent. Recommendation: We recommend that the Authority implement internal controls to ensure tenant reasonable rent files are maintained with adequate documentation. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reporting PIC Assistance Listing Number: 14.871 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for the Moving To Work Program, "The information on [HUD-50058, Family Report] is submitted to HUD through the Inventory Management System/Public and Indian Housing Information Center (IMS/PIC). [...] Data must be submitted 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." Condition: The Authority did not have adequate internal controls designed to ensure that all HUD-50058s were properly uploaded to the PIC system. Special Tests: -PIC testing Context: During our testing over PIC, auditor noted 1 of the 40 selections tested had no updated HUD-50058 form in accordance with OMB Compliance Supplement criteria. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that PIC uploads were processed accordingly. Effect: The Authority is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months. The Authority is also not in compliance with its own administrative policy on the HCV program. Recommendation: We recommend that the Authority implement a higher-level review of the HUD-50058 listing that gets uploaded to the PIC system. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: (1) According to the Authority's internal procedures, case managers are to complete a checklist to keep in tenant file any time a new computation is created, be that for an annual, interim, or special reexamination. This must be signed and dated by the completing caseworker. (2) According to the compliance supplement for the Housing Voucher Cluster, "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). 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). Condition: The Authority did not have adequate internal controls designed to ensure that all proper documentation was signed. Special Tests: -Eligibility Context: During our testing over eligibility, auditor noted 3 of the 40 selections tested had missing signed documentation that the Authority had to have the tenant sign in accordance with the Authority’s internal procedures and compliance supplement for Housing Voucher Cluster program. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure it is meeting eligibility requirements set by HUD. Effect: The Authority is not in compliance with program requirements over eligibility. Recommendation: We recommend the Authority implement processes to ensure that all proper documentation is being maintained during the process for every tenant. Views of Responsible Officials: There is no disagreement with the audit finding.

HCVP Depository Agreement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Federal Award Identification Number and Year: OR005 – 2024 Assistance Listing Number: 14.871 / 14.879 Award Period: January 1, 2024 through December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD. The agreements serve as safeguards for federal funds and provide third-party rights to HUD. Among the terms in many agreements are requirements for funds to be placed in an interest-bearing account (24 CFR section 982.156). Condition: The Authority did not have adequate internal controls designed to ensure that depository agreements are maintained for banks that hold HUD funds. Context: During our testing, we noted the Authority did not have a depository agreement with its’ financial institution in the form required by HUD funds. Questioned costs: None Cause: The Authority does not have controls in place to ensure it is meeting all requirements set by HUD. Effect: The Authority is not in compliance with program requirements. Recommendation: The Authority should obtain depository agreements for all bank accounts required by HUD. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reasonable Rent Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for HCVP program. "The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner." Condition: HALC was unable to provide the necessary documentation to support the following Housing Voucher Cluster compliance requirements: Special Tests: -Reasonable rent Context: During our testing over reasonable rent, auditor noted 1 of the 40 selections tested had no documentation that their determination of rent to owners is reasonable in accordance with their administrative plan at initial leasing and during the term of the contract as required. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that reasonable rent files are processed accordingly. Effect: The Authority is not in compliance with program requirements over reasonable rent. Recommendation: We recommend that the Authority implement internal controls to ensure tenant reasonable rent files are maintained with adequate documentation. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reporting PIC Assistance Listing Number: 14.871 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for the Moving To Work Program, "The information on [HUD-50058, Family Report] is submitted to HUD through the Inventory Management System/Public and Indian Housing Information Center (IMS/PIC). [...] Data must be submitted 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." Condition: The Authority did not have adequate internal controls designed to ensure that all HUD-50058s were properly uploaded to the PIC system. Special Tests: -PIC testing Context: During our testing over PIC, auditor noted 1 of the 40 selections tested had no updated HUD-50058 form in accordance with OMB Compliance Supplement criteria. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that PIC uploads were processed accordingly. Effect: The Authority is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months. The Authority is also not in compliance with its own administrative policy on the HCV program. Recommendation: We recommend that the Authority implement a higher-level review of the HUD-50058 listing that gets uploaded to the PIC system. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: (1) According to the Authority's internal procedures, case managers are to complete a checklist to keep in tenant file any time a new computation is created, be that for an annual, interim, or special reexamination. This must be signed and dated by the completing caseworker. (2) According to the compliance supplement for the Housing Voucher Cluster, "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). 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). Condition: The Authority did not have adequate internal controls designed to ensure that all proper documentation was signed. Special Tests: -Eligibility Context: During our testing over eligibility, auditor noted 3 of the 40 selections tested had missing signed documentation that the Authority had to have the tenant sign in accordance with the Authority’s internal procedures and compliance supplement for Housing Voucher Cluster program. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure it is meeting eligibility requirements set by HUD. Effect: The Authority is not in compliance with program requirements over eligibility. Recommendation: We recommend the Authority implement processes to ensure that all proper documentation is being maintained during the process for every tenant. Views of Responsible Officials: There is no disagreement with the audit finding.

HCVP Depository Agreement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Federal Award Identification Number and Year: OR005 – 2024 Assistance Listing Number: 14.871 / 14.879 Award Period: January 1, 2024 through December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD. The agreements serve as safeguards for federal funds and provide third-party rights to HUD. Among the terms in many agreements are requirements for funds to be placed in an interest-bearing account (24 CFR section 982.156). Condition: The Authority did not have adequate internal controls designed to ensure that depository agreements are maintained for banks that hold HUD funds. Context: During our testing, we noted the Authority did not have a depository agreement with its’ financial institution in the form required by HUD funds. Questioned costs: None Cause: The Authority does not have controls in place to ensure it is meeting all requirements set by HUD. Effect: The Authority is not in compliance with program requirements. Recommendation: The Authority should obtain depository agreements for all bank accounts required by HUD. View of Responsible Officials: There is no disagreement with the audit finding.

HCVP Depository Agreement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Federal Award Identification Number and Year: OR005 – 2024 Assistance Listing Number: 14.871 / 14.879 Award Period: January 1, 2024 through December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: PHAs are required to enter into depository agreements with their financial institutions in the form required by HUD. The agreements serve as safeguards for federal funds and provide third-party rights to HUD. Among the terms in many agreements are requirements for funds to be placed in an interest-bearing account (24 CFR section 982.156). Condition: The Authority did not have adequate internal controls designed to ensure that depository agreements are maintained for banks that hold HUD funds. Context: During our testing, we noted the Authority did not have a depository agreement with its’ financial institution in the form required by HUD funds. Questioned costs: None Cause: The Authority does not have controls in place to ensure it is meeting all requirements set by HUD. Effect: The Authority is not in compliance with program requirements. Recommendation: The Authority should obtain depository agreements for all bank accounts required by HUD. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reasonable Rent Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for HCVP program. "The PHA’s administrative plan must state the method used by the PHA to determine that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. The PHA determination must consider unit attributes such as the location, quality, size, unit type, and age of the unit, and any amenities, housing services, maintenance, and utilities provided by the owner." Condition: HALC was unable to provide the necessary documentation to support the following Housing Voucher Cluster compliance requirements: Special Tests: -Reasonable rent Context: During our testing over reasonable rent, auditor noted 1 of the 40 selections tested had no documentation that their determination of rent to owners is reasonable in accordance with their administrative plan at initial leasing and during the term of the contract as required. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that reasonable rent files are processed accordingly. Effect: The Authority is not in compliance with program requirements over reasonable rent. Recommendation: We recommend that the Authority implement internal controls to ensure tenant reasonable rent files are maintained with adequate documentation. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Reporting PIC Assistance Listing Number: 14.871 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: According to the OMB Compliance Supplement for the Moving To Work Program, "The information on [HUD-50058, Family Report] is submitted to HUD through the Inventory Management System/Public and Indian Housing Information Center (IMS/PIC). [...] Data must be submitted 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." Condition: The Authority did not have adequate internal controls designed to ensure that all HUD-50058s were properly uploaded to the PIC system. Special Tests: -PIC testing Context: During our testing over PIC, auditor noted 1 of the 40 selections tested had no updated HUD-50058 form in accordance with OMB Compliance Supplement criteria. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure that PIC uploads were processed accordingly. Effect: The Authority is not in compliance with federal regulations regarding the recertification of household circumstances within 12 months. The Authority is also not in compliance with its own administrative policy on the HCV program. Recommendation: We recommend that the Authority implement a higher-level review of the HUD-50058 listing that gets uploaded to the PIC system. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster – Program Documentation (Significant Deficiency) Assistance Listing Number: 14.871 Federal Award Identification Number and Year: OR005 – 2024 Award Period: January 1, 2024 – December 31, 2024 Compliance Requirement: Special Tests and Provisions – Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: (1) According to the Authority's internal procedures, case managers are to complete a checklist to keep in tenant file any time a new computation is created, be that for an annual, interim, or special reexamination. This must be signed and dated by the completing caseworker. (2) According to the compliance supplement for the Housing Voucher Cluster, "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). 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). Condition: The Authority did not have adequate internal controls designed to ensure that all proper documentation was signed. Special Tests: -Eligibility Context: During our testing over eligibility, auditor noted 3 of the 40 selections tested had missing signed documentation that the Authority had to have the tenant sign in accordance with the Authority’s internal procedures and compliance supplement for Housing Voucher Cluster program. Questioned costs: None Cause: The Authority did not have adequate internal controls designed to ensure it is meeting eligibility requirements set by HUD. Effect: The Authority is not in compliance with program requirements over eligibility. Recommendation: We recommend the Authority implement processes to ensure that all proper documentation is being maintained during the process for every tenant. Views of Responsible Officials: There is no disagreement with the audit finding.