Finding 2022-002 ? Insufficient Collateralization of Deposits (Other Matter) Public Housing Program ? Assistance Listing No. 14.850a, Grant Period: Fiscal Year-End June 30, 2022 Criteria HUD PIH Notice 96-33 requires PHA?s to continuously and fully secure all bank deposits which exceed federally-insured balances. Condition, Cause and Perspective As of June 30, 2022, the Authority?s bank deposit balances were under-collateralized by $34,757. Questioned Costs ? None Effect Non-compliance with HUD PIH Notice 96-33. Recommendation We recommend that the Authority monitor security over bank deposits regularly. Management?s Response The Authority will monitor security over bank deposits regularly. The Authority?s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2023.
Finding 2022-004 ? Unallowable Use of Public Housing Program Funds (Significant Deficiency, Non-compliance) Public Housing Program ? Assistance Listing No. 14.850a, Grant Period: Fiscal Year-End June 30, 2022 Criteria The cost principles in 2 CFR Part 200, Sub-part E of the Uniform Guidance describe allowable and unallowable uses of federal award program subsidies. Parts 200.403 and 200.405 prohibit the use of federal award program subsidies to fund expenditures outside of the applicable federal award program. Public Housing Program funds cannot be used to fund expenditures and/or deficits of other federal or non-federal programs. HUD Handbook 7475.1 defines allowable expenditures under Public Housing Program versus expenditures of the Central Office Cost Center (COCC). Equipment purchases of the COCC should not be charged to the Public Housing Program. Condition, Cause, Perspective and Questioned Costs During fiscal year 2022, the Authority charged the purchase of an administrative vehicle, in the amount of $35,256, to the Public Housing Program. Effect Non-compliance with federal requirements with respect to the Public Housing Program. Recommendation We recommend that the Authority review allowable Public Housing Program versus COCC expenditures in HUD Handbook 7575.1 and refrain from charging COCC expenditures to the Public Housing Program. Management?s Response The Authority review allowable Public Housing Program versus COCC expenditures in HUD Handbook 7575.1 and refrain from charging COCC expenditures to the Public Housing Program. The Authority?s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2023.
Finding 2022-003 ? Non-compliance with Internal Procurement Policy (Material Weakness, Material Non-Compliance) Capital Fund Program ? Assistance Listing No. 14.872, Grant Period: Fiscal Year-End June 30, 2022 Criteria Public Housing Authorities (PHA?s) should procure federally-funded contracts in accordance with a formal, documented internal Procurement Policy based on federal procurement guidelines, including HUD Handbook 7460.8, Rev. 2, Procurement Handbook for Public Housing Agencies. PHA?s are prohibited from awarding contracts to contractors who have been suspended or debarred from performing contracts funded with federal subsidies. Additionally, the Authority?s Procurement Policy states that a contract should not be awarded until the prospective contractor has been determined not to be suspended or debarred. PHA?s are permitted to comply with the applicable regulations by A) searching the Excluded Parties List System (EPLS) for the prospective contractor, or B) attaining a certified statement from the contractor in which the contractor certifies against suspension or debarment. Condition, Cause and Perspective Two Capital Fund Program funded contract awards were sampled. One applicable contact, awarded in the amount of $120,725, did not contain the contractor?s certification against suspension and debarment or evidence that the EPLS was searched for the contractor. Questioned Costs - $76,705 was expended under the contract during fiscal year 2022. Effect Non-compliance with the Authority?s Procurement Policy and federal regulations. Recommendation We recommend that the Authority attain certification against suspension and debarment or search the EPLS for prospective contractors prior to awarding contracts. Management?s Response The Authority will attain certification against suspension and debarment or search the EPLS for prospective contractors prior to awarding contracts. The Authority?s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2023.
Finding 2022-002 ? Insufficient Collateralization of Deposits (Other Matter) Public Housing Program ? Assistance Listing No. 14.850a, Grant Period: Fiscal Year-End June 30, 2022 Criteria HUD PIH Notice 96-33 requires PHA?s to continuously and fully secure all bank deposits which exceed federally-insured balances. Condition, Cause and Perspective As of June 30, 2022, the Authority?s bank deposit balances were under-collateralized by $34,757. Questioned Costs ? None Effect Non-compliance with HUD PIH Notice 96-33. Recommendation We recommend that the Authority monitor security over bank deposits regularly. Management?s Response The Authority will monitor security over bank deposits regularly. The Authority?s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2023.
Finding 2022-004 ? Unallowable Use of Public Housing Program Funds (Significant Deficiency, Non-compliance) Public Housing Program ? Assistance Listing No. 14.850a, Grant Period: Fiscal Year-End June 30, 2022 Criteria The cost principles in 2 CFR Part 200, Sub-part E of the Uniform Guidance describe allowable and unallowable uses of federal award program subsidies. Parts 200.403 and 200.405 prohibit the use of federal award program subsidies to fund expenditures outside of the applicable federal award program. Public Housing Program funds cannot be used to fund expenditures and/or deficits of other federal or non-federal programs. HUD Handbook 7475.1 defines allowable expenditures under Public Housing Program versus expenditures of the Central Office Cost Center (COCC). Equipment purchases of the COCC should not be charged to the Public Housing Program. Condition, Cause, Perspective and Questioned Costs During fiscal year 2022, the Authority charged the purchase of an administrative vehicle, in the amount of $35,256, to the Public Housing Program. Effect Non-compliance with federal requirements with respect to the Public Housing Program. Recommendation We recommend that the Authority review allowable Public Housing Program versus COCC expenditures in HUD Handbook 7575.1 and refrain from charging COCC expenditures to the Public Housing Program. Management?s Response The Authority review allowable Public Housing Program versus COCC expenditures in HUD Handbook 7575.1 and refrain from charging COCC expenditures to the Public Housing Program. The Authority?s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2023.
Finding 2022-003 ? Non-compliance with Internal Procurement Policy (Material Weakness, Material Non-Compliance) Capital Fund Program ? Assistance Listing No. 14.872, Grant Period: Fiscal Year-End June 30, 2022 Criteria Public Housing Authorities (PHA?s) should procure federally-funded contracts in accordance with a formal, documented internal Procurement Policy based on federal procurement guidelines, including HUD Handbook 7460.8, Rev. 2, Procurement Handbook for Public Housing Agencies. PHA?s are prohibited from awarding contracts to contractors who have been suspended or debarred from performing contracts funded with federal subsidies. Additionally, the Authority?s Procurement Policy states that a contract should not be awarded until the prospective contractor has been determined not to be suspended or debarred. PHA?s are permitted to comply with the applicable regulations by A) searching the Excluded Parties List System (EPLS) for the prospective contractor, or B) attaining a certified statement from the contractor in which the contractor certifies against suspension or debarment. Condition, Cause and Perspective Two Capital Fund Program funded contract awards were sampled. One applicable contact, awarded in the amount of $120,725, did not contain the contractor?s certification against suspension and debarment or evidence that the EPLS was searched for the contractor. Questioned Costs - $76,705 was expended under the contract during fiscal year 2022. Effect Non-compliance with the Authority?s Procurement Policy and federal regulations. Recommendation We recommend that the Authority attain certification against suspension and debarment or search the EPLS for prospective contractors prior to awarding contracts. Management?s Response The Authority will attain certification against suspension and debarment or search the EPLS for prospective contractors prior to awarding contracts. The Authority?s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2023.