Audit 368641

2024 – 001: Income and Asset Verification Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Federal Award Identification Number and Year: WI183VO- 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: For both family income examinations and reexaminations, 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 985.516). 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.) (24 CFR sections 982.201, 982.515, and 982.516). Condition: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: None Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not maintain evidence of completion of income verification as a part of the annual re-examination, three (3) tenant files had clerical errors of the income calculation reported on the HUD 50058, and one (1) tenant files did not contain third party verification of assets. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 985.516. Repeat Finding: Yes; 2023-003 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2024 – 002: Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Federal Award Identification Number and Year: WI183VO- 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHS must maintain records to document the bases for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: None Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not include documentation of performance of rent reasonableness prior to the lease date. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: 2023-004 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2024 – 003: Utility Allowance Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Federal Award Identification Number and Year: WI183VO- 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised. Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: None Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not include proper documentation of utility allowance. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: 2023-005 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2024 – 004: Housing Quality Standards (HQS) Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Federal Award Identification Number and Year: WI183VO- 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (HQS), the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: During our testing, we noted the Authority failed to comply with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: None Context: From a sample of thirty-four (34) program participant files selected for testing, we noted two (2) instances where the repairs were not completed within 30 days and three (3) instances where life threating repairs were not completed within 24 HRs in accordance with the stated criteria and the HAP was not held. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2023-007 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.