Program Information:
U.S. Department of Housing and Urban Development
Indian Housing Block Grant
Assistance Listing #14.867
Award Numbers: 55-IH-53-18320
Award Period: 10/18/2011 – 09/30/2034
Criteria: Per the 2024 OMB Compliance Supplement, each recipient shall develop written policies governing the eligibility, admission, and occupancy of families for housing assisted with grant funds (25 USC 4133(d)).
Per YNHA policies, all program applicants must meet the following eligibility requirements:
• Qualify as an Indian Family or qualify for an exception - YNHA may decide to provide housing assistance for non-Indian family if they deem the presence of the family on the reservation is essential to the well-being of Indian families and the need for housing of essential families cannot reasonably be met without such assistance (ex. teachers, healthcare providers). Executive Director will make a determination for essential families. YNHA may also provide housing for law enforcement officers of the Nation or another unit of government and YNHA determines the presence of the officer may deter crime.
• Have an annual income that meets income eligibility standards (considered low-income based on HUD thresholds) or qualify as an exception. Families that are not low-income can receive assistance in a few cases: they were low income at the time of initial occupancy, they received a Mutual Help unit through transfer of the unit from a family member, or the family is an essential family/law enforcement (see above).
• Be 18 years or older or 16 with status as an emancipated minor.
• Provide a complete application including proof of tribal enrollment, social security cards, and proof of income.
• Signed Consent for Release of Information to YNHA/HUD Form 9886.
• Must submit to drug and alcohol screening tests prior to signing the rental agreement, lease, or homeownership agreement.
• Annual inspections.
2 CFR § 200.303 - Internal controls states, the non-federal entity must:
(a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: During testing of 30 tenant files under the IHBG program:
• 2 of 30 files did not include a signed rental agreement documenting initial eligibility approval.
• 30 of 30 files lacked evidence of approval of recertifications or required inspections.
[ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness
Cause: YNHA’s internal control procedures over eligibility and recertification were not consistently followed. Management did not ensure that signed agreements and approvals of recertifications/inspections were documented in the tenant files.
Effect: Failure to document eligibility determinations and approvals creates a risk that ineligible tenants may receive housing benefits, that federal program requirements may not be met, and that YNHA may be subject to HUD compliance findings.
Questioned Cost: N/A – The documentation deficiencies identified did not result in known unallowable costs or payments to ineligible participants; therefore, no questioned costs are reported.
Prior Year Finding: No.
Recommendation: We recommend that YNHA implement written procedures and staff training to ensure all required eligibility and occupancy documentation is obtained and retained.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Housing and Urban Development
Indian Housing Block Grant
Assistance Listing #14.867
Award Numbers: 55-IH-53-18320
Award Period: 10/18/2011 – 09/30/2034
Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200.
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the suspension and debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension,” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award.
2 CFR § 200.303 - Internal controls states, the non-federal entity must:
(a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: 2 of 4 samples selected for suspension and debarment testing did not have documentation of a suspension and debarment search performed prior to entering a transaction with the vendor.
[ X ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness
Cause: There were ineffective controls in place during the period, along with management oversight.
Effect: YNHA may unknowingly enter into business with a suspended or debarred vendor.
Questioned Cost: N/A – While documentation of the suspension and debarment verification was not available, no evidence was identified indicating that payments were made to suspended or debarred parties. Therefore, no questioned costs were identified.
Prior Year Finding: No.
Recommendation: We recommend YNHA conduct a training for staff and program managers to review YNHA’s suspension and debarment requirements and perform searches annually.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Housing and Urban Development
Indian Housing Block Grant
Assistance Listing #14.867
Award Numbers: 55-IH-53-18320
Award Period: 10/18/2011 – 09/30/2034
Criteria: Per the 2024 OMB Compliance Supplement:
Program regulations provide that a tribe may assume responsibilities for environmental review and decision making under the requirements of 24 CFR Part 58 or it may allow HUD to retain these responsibilities. The tribe is the responsible entity, whether or not a TDHE is authorized to receive IHBG grant amounts on behalf of the tribe (24 CFR section 58.2(a)(7)(ii)). If HUD retains the responsibilities, HUD will do reviews under the provisions of 24 CFR Part 50 (24 CFR section 1000.20). A HUD environmental review must be completed for any activities not excluded before a recipient may acquire, rehabilitate, convert, lease, repair, or construct property, or commit HUD or local funds (24 CFR section 1000.20(a)).
If the tribe assumes these responsibilities, the following applies: An environmental review must be prepared for each project or activity. Funds may not be committed to a grant activity or project before the completion of the environmental review and approval of the Request for Release of Funds (RROF) and environmental certification. If the responsible entity tribe determines that it met a criterion specified in the regulations that would qualify the project as exempt or qualify the project for certain categorical exclusions, the RROF and environmental certification requirements do not apply (24 CFR sections 58.34 and 58.35(b), 24 CFR section 1000.20(b)(3)).
2 CFR § 200.303 - Internal controls states, the non-federal entity must:
(a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: During testing, we noted that 1 of 3 environmental review samples had expenditures prior to approval of the environmental review.
[ X ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness
Cause: Lack of internal controls over environmental reviews.
Effect: If funds are expended prior to completion of the environmental review, they may be in violation of environmental laws and out of compliance with the program. The funds may also be used for projects where the review determines there were significant or unavoidable environmental impacts, and it should not have started.
Questioned Cost: N/A – Although expenditures were incurred prior to approval of the environmental review, the costs tested were ultimately allowable under the program, supported by adequate documentation, and not prohibited by regulation. Therefore, no costs required adjustment or repayment.
Prior Year Finding: No.
Recommendation: We recommend YNHA ensure environmental reviews are approved prior to beginning work on the project.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Housing and Urban Development
Indian Housing Block Grant
Assistance Listing #14.867
Award Numbers: 55-IH-53-18320
Award Period: 10/18/2011 – 09/30/2034
Criteria: Per the 2024 OMB Compliance Supplement, each recipient shall develop written policies governing the eligibility, admission, and occupancy of families for housing assisted with grant funds (25 USC 4133(d)).
Per YNHA policies, all program applicants must meet the following eligibility requirements:
• Qualify as an Indian Family or qualify for an exception - YNHA may decide to provide housing assistance for non-Indian family if they deem the presence of the family on the reservation is essential to the well-being of Indian families and the need for housing of essential families cannot reasonably be met without such assistance (ex. teachers, healthcare providers). Executive Director will make a determination for essential families. YNHA may also provide housing for law enforcement officers of the Nation or another unit of government and YNHA determines the presence of the officer may deter crime.
• Have an annual income that meets income eligibility standards (considered low-income based on HUD thresholds) or qualify as an exception. Families that are not low-income can receive assistance in a few cases: they were low income at the time of initial occupancy, they received a Mutual Help unit through transfer of the unit from a family member, or the family is an essential family/law enforcement (see above).
• Be 18 years or older or 16 with status as an emancipated minor.
• Provide a complete application including proof of tribal enrollment, social security cards, and proof of income.
• Signed Consent for Release of Information to YNHA/HUD Form 9886.
• Must submit to drug and alcohol screening tests prior to signing the rental agreement, lease, or homeownership agreement.
• Annual inspections.
2 CFR § 200.303 - Internal controls states, the non-federal entity must:
(a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: During testing of 30 tenant files under the IHBG program:
• 2 of 30 files did not include a signed rental agreement documenting initial eligibility approval.
• 30 of 30 files lacked evidence of approval of recertifications or required inspections.
[ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness
Cause: YNHA’s internal control procedures over eligibility and recertification were not consistently followed. Management did not ensure that signed agreements and approvals of recertifications/inspections were documented in the tenant files.
Effect: Failure to document eligibility determinations and approvals creates a risk that ineligible tenants may receive housing benefits, that federal program requirements may not be met, and that YNHA may be subject to HUD compliance findings.
Questioned Cost: N/A – The documentation deficiencies identified did not result in known unallowable costs or payments to ineligible participants; therefore, no questioned costs are reported.
Prior Year Finding: No.
Recommendation: We recommend that YNHA implement written procedures and staff training to ensure all required eligibility and occupancy documentation is obtained and retained.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Housing and Urban Development
Indian Housing Block Grant
Assistance Listing #14.867
Award Numbers: 55-IH-53-18320
Award Period: 10/18/2011 – 09/30/2034
Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200.
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the suspension and debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension,” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award.
2 CFR § 200.303 - Internal controls states, the non-federal entity must:
(a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: 2 of 4 samples selected for suspension and debarment testing did not have documentation of a suspension and debarment search performed prior to entering a transaction with the vendor.
[ X ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness
Cause: There were ineffective controls in place during the period, along with management oversight.
Effect: YNHA may unknowingly enter into business with a suspended or debarred vendor.
Questioned Cost: N/A – While documentation of the suspension and debarment verification was not available, no evidence was identified indicating that payments were made to suspended or debarred parties. Therefore, no questioned costs were identified.
Prior Year Finding: No.
Recommendation: We recommend YNHA conduct a training for staff and program managers to review YNHA’s suspension and debarment requirements and perform searches annually.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Housing and Urban Development
Indian Housing Block Grant
Assistance Listing #14.867
Award Numbers: 55-IH-53-18320
Award Period: 10/18/2011 – 09/30/2034
Criteria: Per the 2024 OMB Compliance Supplement:
Program regulations provide that a tribe may assume responsibilities for environmental review and decision making under the requirements of 24 CFR Part 58 or it may allow HUD to retain these responsibilities. The tribe is the responsible entity, whether or not a TDHE is authorized to receive IHBG grant amounts on behalf of the tribe (24 CFR section 58.2(a)(7)(ii)). If HUD retains the responsibilities, HUD will do reviews under the provisions of 24 CFR Part 50 (24 CFR section 1000.20). A HUD environmental review must be completed for any activities not excluded before a recipient may acquire, rehabilitate, convert, lease, repair, or construct property, or commit HUD or local funds (24 CFR section 1000.20(a)).
If the tribe assumes these responsibilities, the following applies: An environmental review must be prepared for each project or activity. Funds may not be committed to a grant activity or project before the completion of the environmental review and approval of the Request for Release of Funds (RROF) and environmental certification. If the responsible entity tribe determines that it met a criterion specified in the regulations that would qualify the project as exempt or qualify the project for certain categorical exclusions, the RROF and environmental certification requirements do not apply (24 CFR sections 58.34 and 58.35(b), 24 CFR section 1000.20(b)(3)).
2 CFR § 200.303 - Internal controls states, the non-federal entity must:
(a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: During testing, we noted that 1 of 3 environmental review samples had expenditures prior to approval of the environmental review.
[ X ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness
Cause: Lack of internal controls over environmental reviews.
Effect: If funds are expended prior to completion of the environmental review, they may be in violation of environmental laws and out of compliance with the program. The funds may also be used for projects where the review determines there were significant or unavoidable environmental impacts, and it should not have started.
Questioned Cost: N/A – Although expenditures were incurred prior to approval of the environmental review, the costs tested were ultimately allowable under the program, supported by adequate documentation, and not prohibited by regulation. Therefore, no costs required adjustment or repayment.
Prior Year Finding: No.
Recommendation: We recommend YNHA ensure environmental reviews are approved prior to beginning work on the project.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.