Audit 367174

2024-003 HUD Required Reporting Criteria HUD regulations and federal requirements mandate timely submission of the Financial Assessment Subsystem for Public Housing Agencies (FASSPHA), the Data Collection Form (SF-SAC) for the Single Audit, and the Section Eight Management Assessment Program (SEMAP) reports. These submissions are critical for ensuring compliance, enabling oversight, and facilitating the allocation of federal funding. Condition It was identified during the audit that the Authority did not meet the prescribed deadlines for submitting the FASSPHA, and SF-SAC reports to federal agencies. This delay in reporting has been noted for the first time in the 2021 audit findings. Context This lapse was identified against a backdrop of the Authority traditionally maintaining a good track record with reporting. The recent delays mark a departure from their usual compliance practices and have occurred amidst organizational changes and challenges, including staff turnover and procedural adjustments within the finance department. Cause The failure to meet reporting deadlines can be attributed to a combination of factors, including major staff turnover, which led to a loss of institutional knowledge and expertise critical for the preparation and submission of these reports. These challenges were compounded by inefficiencies in the Authority’s internal processes for report preparation and submission. Effect The failure to submit these reports on time undermines the Authority’s compliance with federal regulations, potentially affecting its eligibility for future funding and leading to reputational damage. It may also delay financial and operational decisions by HUD that depend on the analysis of these reports. Recommendations It is recommended that the Authority: (1) Prioritize the recruitment and training of new staff to fill critical roles, ensuring they are well-versed in HUD reporting requirements; (2) Establish a contingency plan for maintaining continuity of operations in the event of key personnel turnover or unavailability; and (3) Revise and streamline internal reporting processes to improve efficiency and reliability in meeting HUD's reporting deadlines. Questioned Costs None. Management Views Management acknowledges the audit findings and is committed to taking corrective actions.

2024-004 Eligibility Controls and Compliance Criteria As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516) Condition Incomplete documentation of tenant’s income eligibility for participation in the Housing Choice Voucher Program. During the sampling of forty (40) tenant files we noted: (A) seven (7) did not include utility allowance calculation; (B) two (2) 50058 forms did not agree with the Housing Assistance Payments made to landlords; (C) two (2) tenant rents did not fall between 90% and 110% of the HUD FMR for the areas; and (D) four (4) of the selected tenants did not have a file that could be located during our testing. Context The Authority manages over 600 Housing Choice Vouchers and 600 Port-In Voucher during the year. We sampled 40 tenant files for multiple compliance requirements. Cause The failure to meet compliance requirements noted above can be attributed to a combination of factors, including major staff turnover, which led to a loss of institutional knowledge and expertise critical for the preparation and maintain the required documentation in tenant files. Effect Compliance with income limits and eligibility could not be demonstrated for sampled tenants. Therefore, ineligible individuals may be receiving HAP assistance and /or HAP is being incorrectly calculated based on unverified incomes. Recommendations It is recommended that the Authority: (1) Prioritize the recruitment and training of new staff to fill critical roles, ensuring they are well-versed in HUD requirements and (2) Revise and streamline internal processes to improve efficiency and reliability in meeting HUD's requirements for determining tenant eligibility. Questioned Costs The exact monetary impact needs further investigation to determine the amount for the period of non-compliance. Management Views We agree with this finding and have outlined our plan of action in our Corrective Action Plan.

2024-003 HUD Required Reporting Criteria HUD regulations and federal requirements mandate timely submission of the Financial Assessment Subsystem for Public Housing Agencies (FASSPHA), the Data Collection Form (SF-SAC) for the Single Audit, and the Section Eight Management Assessment Program (SEMAP) reports. These submissions are critical for ensuring compliance, enabling oversight, and facilitating the allocation of federal funding. Condition It was identified during the audit that the Authority did not meet the prescribed deadlines for submitting the FASSPHA, and SF-SAC reports to federal agencies. This delay in reporting has been noted for the first time in the 2021 audit findings. Context This lapse was identified against a backdrop of the Authority traditionally maintaining a good track record with reporting. The recent delays mark a departure from their usual compliance practices and have occurred amidst organizational changes and challenges, including staff turnover and procedural adjustments within the finance department. Cause The failure to meet reporting deadlines can be attributed to a combination of factors, including major staff turnover, which led to a loss of institutional knowledge and expertise critical for the preparation and submission of these reports. These challenges were compounded by inefficiencies in the Authority’s internal processes for report preparation and submission. Effect The failure to submit these reports on time undermines the Authority’s compliance with federal regulations, potentially affecting its eligibility for future funding and leading to reputational damage. It may also delay financial and operational decisions by HUD that depend on the analysis of these reports. Recommendations It is recommended that the Authority: (1) Prioritize the recruitment and training of new staff to fill critical roles, ensuring they are well-versed in HUD reporting requirements; (2) Establish a contingency plan for maintaining continuity of operations in the event of key personnel turnover or unavailability; and (3) Revise and streamline internal reporting processes to improve efficiency and reliability in meeting HUD's reporting deadlines. Questioned Costs None. Management Views Management acknowledges the audit findings and is committed to taking corrective actions.

2024-004 Eligibility Controls and Compliance Criteria As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516) Condition Incomplete documentation of tenant’s income eligibility for participation in the Housing Choice Voucher Program. During the sampling of forty (40) tenant files we noted: (A) seven (7) did not include utility allowance calculation; (B) two (2) 50058 forms did not agree with the Housing Assistance Payments made to landlords; (C) two (2) tenant rents did not fall between 90% and 110% of the HUD FMR for the areas; and (D) four (4) of the selected tenants did not have a file that could be located during our testing. Context The Authority manages over 600 Housing Choice Vouchers and 600 Port-In Voucher during the year. We sampled 40 tenant files for multiple compliance requirements. Cause The failure to meet compliance requirements noted above can be attributed to a combination of factors, including major staff turnover, which led to a loss of institutional knowledge and expertise critical for the preparation and maintain the required documentation in tenant files. Effect Compliance with income limits and eligibility could not be demonstrated for sampled tenants. Therefore, ineligible individuals may be receiving HAP assistance and /or HAP is being incorrectly calculated based on unverified incomes. Recommendations It is recommended that the Authority: (1) Prioritize the recruitment and training of new staff to fill critical roles, ensuring they are well-versed in HUD requirements and (2) Revise and streamline internal processes to improve efficiency and reliability in meeting HUD's requirements for determining tenant eligibility. Questioned Costs The exact monetary impact needs further investigation to determine the amount for the period of non-compliance. Management Views We agree with this finding and have outlined our plan of action in our Corrective Action Plan.