Audit 403436

2024-001 - Compliance with Reporting Requirements of OMB-Single Audit - Material weakness - Repeated and Modified (Prior Year Finding 2023-001) Federal program information: Funding Agency U.S. Department of Housing and Urban Development Program Title Indian Housing Block Grant Federal Assistance Listing Number 14.867 Condition: The data collection form for the year ended December 31, 2024, was not submitted to the Federal Audit Clearinghouse by the required deadline of September 30, 2025. Furthermore, the Annual Performance Report for the IHBG Grant was not submitted on a timely basis, and the submission of reports for the IHBG ARP and IHBG CARES grants were not received. Criteria: In accordance with Uniform Guidance (2 CFR § 200.320), the Housing Entity is required to submit the Data Collection Form (SF-SAC) to the Federal Audit Clearinghouse within the earlier of (1) 30 calendar days after receipt of the auditor’s report(s), or (2) nine months after the end of the audit period. Further, per 7 CFR § 2500.46, the Housing Entity is required to submit the Annual Performance Report (APR) within 90 days after the end of the reporting period. Although a 30-day extension was granted for the IHBG Grant, the report was still not submitted timely. Additionally, the APRs for the IHBG ARP and IHBG CARES grants were not received, resulting in noncompliance with federal requirements. Cause: The Housing Entity did not submit the Data Collection Form (SF-SAC) and the Annual Performance Reports (APR) for the IHBG Grant within the required timeframes. The delay for the IHBG Grant APR was due to delays in obtaining all necessary information and proper documentation to complete the Single Audit and related reports, while the APRs for the IHBG ARP and IHBG CARES grants were not received. Effect: The Housing Entity was not in compliance with federal regulations for the Annual Performance Reports (APR) and the Data Collection Form (SF-SAC) submissions. Auditor's Recommendation: We recommend that the Housing Entity enhance internal controls to ensure the timely preparation, proper documentation, and submission of the Annual Performance Reports (APR) and the Data Collection Form (SF-SAC). This could include establishing formal timelines, clearly assigning responsibilities, and implementing monitoring procedures to track and meet reporting deadlines.

2024-002 - Internal Control Over Compliance, Material Noncompliance - Eligibility - Material weakness Federal program information: Funding Agency U.S. Department of Housing and Urban Development Program Title Indian Housing Block Grant Federal Assistance Listing Number 14.867 Condition: During testing of tenant files for FY 2024, we noted multiple exceptions indicating deficiencies in compliance and internal controls over tenant eligibility and documentation, including: Inclusion of tenant reported as deceased in 2017, with no supporting evidence of eligibility re- evaluation or proper transfer of occupancy. Missing or incomplete documentation for several sampled tenants, including: Housing applications (4 of 15 samples) Occupancy agreements received but not signed (1 of 15 samples) Income recertifications that were missing or outdated (6 of 15 samples) Inspection reports that were missing or outdated (6 of 15 samples) Criteria: In accordance with 25 USC 4133(d), each grant recipient is required to develop written policies governing the eligibility, admission, and occupancy of families for assisted housing. These policies must include verification of applicant income and an annual redetermination of rent based on recertification of income. The Housing Entity has established such policies, which set the standard for maintaining complete tenant files, verifying eligibility, and ensuring compliance with program requirements. Cause: The Housing Entity did not maintain or provide required documentation for tenant eligibility determinations, which limited the ability to verify compliance with established program policies. Effect: The Housing Entity was unable to demonstrate that eligibility determinations, rent calculations, and adherence to program policies were properly performed for the affected tenants. Auditor's Recommendation: The Housing Entity should implement controls to ensure that all required tenant documentation is accurately obtained, retained, and reviewed, thereby supporting eligibility determinations and compliance with program requirements

2024-003 - Internal Control Over Compliance, Material Noncompliance - Procurement and Suspension and Debarment - Material weakness Federal program information: Funding Agency U.S. Department of Housing and Urban Development Program Title Indian Housing Block Grant Federal Assistance Listing Number 14.867 Condition: During testing of five procurement transactions, exceptions were identified in two instances. In one sample, verification of the vendor’s status in SAM.gov was performed after the contract award date, indicating noncompliance with pre-award suspension and debarment requirements. In another sample related to the purchase of a vehicle, the procurement file was missing evidence of comparative bidding. Criteria: In accordance with 2 CFR §§ 200.318–200.327, non-federal entities must follow documented procurement procedures for federally funded purchases exceeding the micro-purchase threshold. These procedures require full and open competition, appropriate procurement methods based on dollar thresholds, and maintenance of records sufficient to detail the history of procurement, including the method used, selection of contractor, and basis for price. Cause: The Housing Entity did not consistently follow established procurement procedures to ensure adequate competition, proper documentation of the procurement process, and timely verification of vendor eligibility. Effect: The Housing Entity was unable to demonstrate compliance with federal procurement and suspension and debarment requirements due to noncompliance with procurement procedures and untimely vendor verification, constituting a material weakness. Auditor's Recommendation: The Housing Entity should ensure SAM.gov verification is completed before awards, maintain complete procurement documentation, and provide staff training to comply with federal procurement requirements.