Audit 367068

2024-001 – ELIGIBILITY Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Housing Voucher Cluster CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 982.516). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 982.201, 982.515, 982.516). CONDITION As a result of audit procedures, we identified 4 instances of missing income verification and 8 instances of incorrect payment standard. CAUSE The Authority’s system of internal control over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent and the housing assistance payment was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None identified. CONTEXT We selected a sample of 10 from a population of 98. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

2024-002 – SPECIAL TESTS & PROVISIONS: RENT REASONABLENESS Material Weakness/Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 – Housing Voucher Cluster CRITERIA The PHA may not approve a lease until the PHA determines that the initial rent to an owner is a reasonable rent. (2) The PHA must redetermine the reasonable rent: (i) Before any increase in the rent to an owner; (ii) If there is a 10 percent decrease in the published FMR in effect 60 days before the contract anniversary (for the unit size rented by the family) as compared with the FMR in effect 1 year before the contract anniversary. (iii) If directed by HUD. The PHA may also redetermine the reasonable rent at any other time. At all times during the assisted tenancy, the rent to owner may not exceed the reasonable rent as most recently determined or redetermined by the PHA. (24 CFR 982.507). CONDITION As a result of audit procedures, we identified 4 instances where the Authority did not perform rent reasonableness. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS None identified. CONTEXT We selected a sample of 10 from a population of 98. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

2024-003 – REPORTING Material Weakness/Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 – Housing Voucher Cluster CRITERIA Financial Reports (0MB No. 2535-0107) - Financial Assessment Sub- system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The FASSPH system is one of HUD's main monitoring and oversight systems for the HCVP. CONDITION The audited submission was required to be submitted to HUD by March 31, 2025. CAUSE The Authority’s internal control processes were not sufficient to ensure the timely filing of the unaudited FDS. EFFECT As a result of not submitting the FDS timely, HUD was limited in its ability to conduct monitoring and oversight of federal programs. QUESTIONED COSTS None identified. CONTEXT The Authority submits the audited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

2024-004 – SPECIAL TESTS & PROVISIONS: DEPOSITORY AGREEMENT Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 – Housing Voucher Cluster CRITERIA PHAs are required to enter into General Depository Agreements with their financial institution using the HUD-51999 (OMB No. 2577-0075) or a form as required by HUD in the ACC. The agreements serve as safe guards for federal funds and provide third party rights to HUD (Section 9 of the ACC). CONDITION The Authority has no active depository agreements with any financial institutions with which federal funds are deposited. CAUSE The Authority’s treasury controls did not account for the need for depository agreements. EFFECT The Authority’s federal funds are not adequately safeguarded. QUESTIONED COSTS None identified. CONTEXT The Authority deposits federal funds with several different financial institutions; however, none have an executed depository agreement. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority execute depository agreements with all financial institutions as soon as possible. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.