Finding No.: 2025-002 Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: Housing Voucher Cluster Federal Award No.: GQ901AF0162, GQ901AF0163,GQ901AF0164, GQ901AF0165, GQ901AF0166, GQ901AF0167, GQ901AF0168,GQ901AFR125, GQ901AFR224, GQ901AFR324, GQ901AFR424, GQ901AFRU24, GQ901EF0008, GQ901EF0009, GQ901EF0010, GQ901EF0011, GQ901EH0011, GQ901EH0012, GQ901EH0013, GQ901EH0014, GQ901VO0265, GQ901VO0266, GQ901VO0267, GQ901VO0268, GQ901VO0269, GQ901VO0270,GQ901VO0271,GQ901VO0272, GQ901VO0273 Area: Special Tests and Provisions – National Standards for the Physical Inspection of Real Estate (NSPIRE) / Housing Quality Standards Inspections Criteria or specific requirement (including statutory, regulatory or other citation): 24 CFR 982.405(b), Periodic Inspections, states: The Public Housing Authority (PHA) must inspect the unit at least biennially during assisted occupancy to ensure that the unit continues to meet the HQS, except that a small rural PHA, as defined in § 902.101 of this title, must inspect a unit once every three years during assisted occupancy to ensure that the unit continues to meet the HQS. Of 2,894 housing units assisted under the Section 8 Housing Choice Voucher Program, representing total housing assistance payments of $50,156,412, the inspection activity report identified 12 units (0.4%), aggregating $194,763, with deficiencies in meeting the biennial Housing Quality Standards (HQS) inspection requirement: Item No. Voucher Number Last Passed HQS Inspection Total Unallowed HAP Questioned Costs 1 6-03-0198-2327 04/04/22 27,648 27,648 2 6-05-0005-42278 07/12/22 25,320 25,320 3 6-05-0145-47900 07/18/22 12,794 12,794 4 6-05-0241-46089 08/29/23 2,280 2,280 5 6-07-0028-2139 07/19/22 23,996 23,996 6 6-07-0289-52502 05/06/22 28,316 28,316 7 EHV0132 08/23/23 1,076 1,076 8 HCV0521 04/22/22 18,997 18,997 9 HCV1038 03/17/22 5,130 5,130 10 HCV1083 09/12/22 17,987 17,987 11 HCV2024 07/06/22 22,875 22,875 12 HCV2110 07/19/23 8,344 8,344 Total Questioned Cost $194,763 For items 1 through 12, the required inspections were not completed by the established biennial due dates. Cause: GHURA lacks effective monitoring controls over inspection scheduling and tracking, resulting in biennial HQS inspections not being completed timely. Effect or potential effect: GHURA is in noncompliance with applicable special tests and provisions for National Standards for the Physical Inspection of Real Estate (NSPIRE) / Housing Quality Standards Inspections requirements. Questioned costs: $194,763 Identification as a repeat finding: Not applicable. Recommendation: GHURA should strengthen internal controls over inspection monitoring by establishing and enforcing procedures that require periodic reconciliation of inspection activity reports to identify overdue inspections. Management should also implement controls to ensure timely scheduling and completion of biennial HQS inspections and verification of compliance. Views of Responsible Officials: Management disagrees with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.
Finding No.: 2025-003 Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: Housing Voucher Cluster Federal Award No.: GQ901AF0162, GQ901AF0163,GQ901AF0164, GQ901AF0165, GQ901AF0166, GQ901AF0167, GQ901AF0168,GQ901AFR125, GQ901AFR224, GQ901AFR324, GQ901AFR424, GQ901AFRU24, GQ901EF0008, GQ901EF0009, GQ901EF0010, GQ901EF0011, GQ901EH0011, GQ901EH0012, GQ901EH0013, GQ901EH0014, GQ901VO0265, GQ901VO0266, GQ901VO0267, GQ901VO0268, GQ901VO0269, GQ901VO0270,GQ901VO0271,GQ901VO0272, GQ901VO0273 Area: Special Tests and Provisions – Reasonable Rent Criteria or specific requirement (including statutory, regulatory or other citation): 24 CFR 982.507(a)(1) PHA determination states: The PHA may not approve a lease until the PHA determines that the initial rent to owner is a reasonable rent. 24 CFR 982.507(b)(1)(2) Comparability states: The PHA must determine whether the rent to owner is a reasonable rent in comparison to rent for other comparable unassisted units. To make this determination, the PHA must consider: (1) The location, quality, size, unit type, and age of the contract unit; and (2) Any amenities, housing services, maintenance and utilities to be provided by the owner in accordance with the lease. Condition: For seven (9%) of 80 participants tested, GHURA did not consistently use appropriate comparable units when determining rent reasonableness and accepted higher proposed rents than reasonable comparable units. Specifically, comparable units selected for the analysis were not within the same market area as the proposed unit, which is inconsistent with GHURA’s administrative plan. Finding No.: 2025-003, continued Cause: GHURA did not effectively implement review controls to ensure that comparable units were selected from appropriate market area and in accordance with established rent reasonableness procedures. Effect or potential effect: GHURA is not in compliance with applicable special test and provisions requirements. The use of noncomparable units from different market areas may result in rent determinations that do not accurately reflect market conditions. The questioned costs associated with noncompliance for reasonable rents is undeterminable because the appropriate market data comparables cannot be reasonably quantified. Questioned Costs: $0 Identification as a repeat finding: Not applicable. Recommendation: GHURA should incorporate a control step within the rent reasonableness process to ensure key factors, including market area, are verified prior to approval of proposed rents. Views of Responsible Officials: Management disagrees with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.
Finding No.: 2025-004 Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.225 CDBG - Entitlement Grants Cluster Federal Award No.: B23ST660001, COVID-19 B20SW660001, B20ST660001 Area: Reporting - CDBG Financial Summary Report Criteria or specific requirement (including statutory, regulatory or other citation): Grantees are required to submit an accurate annual performance and evaluation report through the Integrated Disbursement and Information System. Conditions: 1. For two (50%) of four key line items in the PR26 – CDBG Financial Summary Report, Program Year 2024, Grant No. B23ST660001, the reported amounts did not agree to the underlying accounting records. This resulted in differences in reported disbursements, total obligations, and credit activity, and led to understated Public Service (PS) cap calculations and Planning and Administration (PA) obligations exceeding the 20 percent limit. Line Item Reported Amount Auditor Calculation Per GL Details Over (Under) Reported Variance 36 Percent Funds Obligated for PS Activities (2.05%) 9.84% (11.89%) 46 Percent Funds Obligated for PA Activities Line 11.89% 25.06% (13.17%) 2. For one (50%) of two key line items in the PR26 – CDBG-CV Financial Summary Report, Program Year 2024, Grant No. B20SW660001, the reported amounts do not agree with underlying accounting records. This resulted in differences between the reported disbursements and actual expenditures for Planning and Administration (PA) activities, resulting for inaccuracy of amounts reported to available cap calculations. Line Item Reported Amount Auditor Calculation Per GL Details Over (Under) Reported Variance 21 Percent of Funds Disbursed for PA Activities (Line 19/Line20) 4.82% 5.20% (0.39%) Finding No.: 2025-004, continued Cause: GHURA did not effectively implement monitoring controls over compliance that is primarily caused by the lack of timely reconciliation and end-user adjustments between IDIS and general ledger records. Effect or potential effect: The failure to effectively monitor and reconcile IDIS and general ledger records may result in inaccurate reporting of disbursements, obligations, and overall grant balances. Questioned Costs: $0 Identification as a repeat finding: 2024-001 Recommendation: Responsible personnel should strengthen monitoring controls over compliance with applicable reporting requirements. Responsible personnel should implement and enforce formal, periodic reconciliations between IDIS and the general ledger to ensure that reported disbursements, obligations, and available balances agree with underlying accounting records. These procedures should include timely end-user adjustments, supervisory review, and documented verification of totals prior to PR26 submissions. Prior to certifying IDIS reports, responsible personnel should examine and maintain underlying accounting records to determine the accuracy and completeness of reported data. Views of Responsible Officials: Management partially concurs with the findings. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.
Finding No.: 2025-005 Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.225 CDBG - Entitlement Grants Cluster Federal Award No.: B19ST660001, B20ST660001, B20SW660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Area: Reporting - Federal Funding Accountability and Transparency Act Criteria or specific requirement (including statutory, regulatory or other citation): Per the Federal Funding Accountability and Transparency Act (FFATA), HUD requires PHAs to report each first-tier subaward of $30,000 or more in federal funds to the Federal Subaward Reporting System (FSRS) by the end of the month following the month in which the subaward was issued. Condition: For two (50%) of four subawards tested, aggregating $2,402,176 of $2,769,050, the subawards were not reported in the Federal Subaward Reporting System (FSRS) as follows: Transactions Tested Subaward Not Reported Dollar Amount of Tested Transactions Subaward Not Reported 2 2 $2,769,050 $2,402,176 Cause: GHURA did not establish or consistently implement internal control policies and procedures relating to timely and accurate reporting of all first-tier subawards in the Federal Subaward Reporting System (FSRS). Effect or potential effect: GHURA is in noncompliance with applicable reporting requirements for FFATA reporting. Questioned costs: $0 Identification as a repeat finding: 2024-001 Finding No.: 2025-005, continued Recommendation: Responsible personnel should establish, implement, and maintain effective internal controls over compliance with applicable FFATA reporting requirements. Specifically, such controls should address identifying, documenting, and timely reporting first-tier subawards to the Federal Subaward Reporting System (FSRS). GHURA should also implement monitoring controls for review and reconciliation of subawards to the FSRS. Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.
Finding No.: 2025-006 Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.225 CDBG - Entitlement Grants Cluster Federal Award No.: B19ST660001, B20ST660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Area: Special Tests and Provisions – Rehabilitation Criteria or specific requirement (including statutory, regulatory or other citation): 24 CFR 570.506(a) states: Each recipient shall establish and maintain sufficient records to enable the Secretary to determine whether the recipient has met the requirements of this part. At a minimum, the following records are needed: (a) Records providing a full description of each activity assisted (or being assisted) with CDBG funds, including its location (if the activity has a geographical locus), the amount of CDBG funds budgeted, obligated and expended for the activity, and the provision in subpart C under which it is eligible. 24 CFR 570.506(b)(10) states: For each activity determined to aid in the prevention or elimination of slums or blight based on the elimination of specific conditions of blight or physical decay not located in a slum or blighted area: (i) A description of the specific condition of blight or physical decay treated; and (ii) For rehabilitation carried out under this category, a description of the specific conditions detrimental to public health and safety which were identified and the details and scope of the CDBG assisted rehabilitation by structure. Condition: For one rehabilitation project tested, totaling $133,052, the recipient did not maintain adequate supporting documentation—such as pre-rehabilitation inspection reports or assessment records—to substantiate the procedures performed in identifying conditions of blight or physical decay. As a result, there was insufficient evidence to support the basis for determining the existence of such conditions or to demonstrate the completeness of the rehabilitation needs identified for the project structure, as required under applicable CDBG recordkeeping requirements. Finding No.: 2025-006, continued Cause: GHURA does not have formal oversight controls for project documentation and assigned project personnel, including the absence of formal procedures requiring the preparation and retention of pre-rehabilitation inspection reports or assessment records. Effect or potential effect: GHURA is in noncompliance with applicable requirements. Questioned Costs: $133,052 Identification as a repeat finding: Not applicable. Recommendation: Management should implement formal procedures to ensure pre-rehabilitation inspections are performed, documented, and retained to support the identified scope of work. Management should improve supervisory review controls to verify that project files contain adequate documentation demonstrating compliance with CDBG recordkeeping requirements prior to approval and funding. Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.
Finding No.: 2025-007 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.239 HOME Investment Partnerships (HOME) Program Federal Award No.: M17ST660202 Area: Eligibility Criteria or specific requirement (including statutory, regulatory or other citation): GHURA’s Renewal Affordable Homes Program Policy, Chapter 3, Part B states: Housing expenses to include principal, interest, taxes and insurance (PITI) cannot exceed thirty-three percent (33%) to qualify for a loan. Condition: For one (25% amounting to $112,500) of four mortgagees tested (amounting to $700,750) of $2,230,031 in total HOME subsidies, a deficiency was noted as follows: Item # Application No. HOME Subsidy Amount Questioned Cost 1 RAHM-U-0035 $112,500 $112,500 For item # 1, the participant was ineligible to participate as the participant’s housing expenses, including PITI, exceeded thirty-three percent (33%) of total income. Cause: There was lapse in adherence to established underwriting procedures, resulting in the approval of a participant whose PITI exceeded the allowable threshold. Effect or potential effect: GHURA is in noncompliance with the applicable requirement. Questioned costs: $112,500 Identification as a repeat finding: Not applicable. Finding No.: 2025-007, continued Recommendation: Responsible personnel should enforce monitoring controls over compliance with applicable maximum per-unit subsidy requirements. Specifically, supervisory personnel should be required to perform effective reviews of applicant files prior to approving HOME assistance to ensure that procedures are followed and calculations are accurate. Views of Responsible Officials: Management concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan.
Finding No.: 2025-008 Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.239 HOME Investment Partnerships (HOME) Program Federal Award No.: M17ST660202, M18ST660202 Area: Special Tests and Provisions – Housing Quality Standards Criteria or specific requirement (including statutory, regulatory or other citation): 24 CFR 92.251states: (a) New construction projects — (2) Construction progress and final inspections. The participating jurisdiction must conduct on-site progress and final inspections of construction to ensure that work is done in accordance with the applicable codes, the construction contract, and construction documents. Before completing the project in the disbursement and information system established by HUD, the participating jurisdiction must perform an on-site inspection of the project to determine that all contracted work has been completed and that the project complies with the property standards and requirements in this paragraph (a). All inspections performed by the participating jurisdiction must be conducted in accordance with the participating jurisdiction's inspection procedures. Condition: For all four (100%) new mortgages, aggregating $700,750 of $2,230,031 in total HOME subsidies, the HOME program did not perform final on-site inspections to confirm the housing meets appropriate property standards. Cause: The HOME program does not have formalized monitoring procedures, including detailed review checklists, to ensure that all required documentation is completed and adequately reviewed prior to the approval and disbursement of HOME subsidies. Finding No.: 2025-008, continued Effect or potential effect: GHURA is in noncompliance with applicable special test and provisions requirements. Questioned Costs: $700,750 Identification as a repeat finding: Not applicable. Recommendation: The HOME program should establish and implement a detailed standardized checklists with reviewer controls, to ensure that all required documentation—particularly evidence of final onsite inspections, is completed and reviewed prior to the approval and disbursement of HOME funds. Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: The condition relates to the support available for review for audit submission. We examined all new mortgagee files submitted on April 10, 2026. Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.
Finding No.: 2025-009 Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.239 HOME Investment Partnerships (HOME) Program Federal Award No.: M17ST660202, M18ST660202 Area: Special Tests and Provisions – Underwriting Criteria or specific requirement (including statutory, regulatory or other citation): 24 CFR 92.254(g) states: Homebuyer program policies. The participating jurisdiction must have and follow written policies for: (1) Underwriting standards for homeownership assistance to determine the amount of assistance necessary to achieve sustainable homeownership. These standards must evaluate the projected overall debt of the family after the purchase of the housing, the maximum amount that a participating jurisdiction may provide a family, the appropriateness of the amount of assistance, assets available to a family to acquire the housing, and financial resources to sustain homeownership. A participating jurisdiction may not provide a single, fixed amount of assistance to each homebuyer that participates in the participating jurisdiction's homebuyer program; (2) Responsible lending, and (3) Refinancing loans to which HOME loans are subordinated to require that the terms of the new loan are reasonable. Condition: The HOME Program did not have an approved policy effective in FY2025. Cause: The condition was primarily due to delays in the formal review, update, and approval of the HOME Program policies to align with applicable federal requirements under 24 CFR 92.254(g). Finding No.: 2025-009, continued Effect or potential effect: GHURA is in noncompliance with applicable special test and provisions requirements. Questioned Costs: $0. No questioned cost is presented as this non-compliance pertains to a lack of policy. Identification as a repeat finding: Not applicable. Recommendation: GHURA should implement a written policy in compliance with the requirements of 24 CFR 92.254(g). Views of Responsible Officials: Management disagrees with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.
Finding No.: 2025-010 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.239 HOME Investment Partnerships (HOME) Program Federal Award No.: M18ST660202, M21ST660202, M22ST660202, M23ST660202 Area: Special Tests and Provisions – Wage Rate Determination Criteria or specific requirement (including statutory, regulatory or other citation): 29 CFR 5.5 states: (a) Required contract clauses. The Agency head will cause or require the contracting officer to require the contracting officer to insert in full, or (for contracts covered by the Federal Acquisition Regulation (48 CFR chapter 1)) by reference, in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the laws referenced by § 5.1, the following clauses (or any modifications thereof to meet the particular needs of the agency, Provided, That such modifications are first approved by the Department of Labor). 29 CFR 5.5(a)(3)(ii) states: (ii) Certified payroll requirements — (A) Frequency and method of submission. The contractor or subcontractor must submit weekly, for each week in which any DBA- or Related Acts-covered work is performed, certified payrolls to the [write in name of appropriate Federal agency] if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the certified payrolls to the applicant, sponsor, owner, or other entity, as the case may be, that maintains such records, for transmission to the [write in name of agency]. The prime contractor is responsible for the submission of all certified payrolls by all subcontractors. A contracting agency or prime contractor may permit or require contractors to submit certified payrolls through an electronic system, as long as the electronic system requires a legally valid electronic signature; the system allows the contractor, the contracting agency, and the Department of Labor to access the certified payrolls upon request for at least 3 years after the work on the prime contract has been completed; and the contracting agency or prime contractor permits other methods of submission in situations where the contractor is unable or limited in its ability to use or access the electronic system. Finding No.: 2025-010, continued Condition: Of the three contractual labor transactions tested, all (100%), totaling $301,011, did not include the required contract clause addressing compliance with the Davis-Bacon and Related Acts, including all applicable rulings and interpretations under 29 CFR Parts 1, 3, and 5. Additionally, for these same contracts, the entity did not enforce the requirement for contractors or subcontractors to submit certified payrolls on a weekly basis for each week in which Davis-Bacon or Related Acts-covered work was performed. Item # Purchase Order Expenditures Questioned Costs 1 241616 $ 99,611 $ 99,611 2 250207 55,400 55,400 3 250994 146,000 146,000 $301,011 $301,011 Cause: Management lacks a formalized process or checklist to ensure that (1) all federally required contract clauses, including those related to Davis-Bacon and Related Acts compliance under 29 CFR Parts 1, 3, and 5, are consistently incorporated into applicable contracts, and (2) contractors and subcontractors are monitored for compliance with certified payroll submission requirements on a weekly basis for all covered work performed. Effect or potential effect: GHURA is in noncompliance for entering into contractual labor without the effect of Compliance with Davis-Bacon and Related Act clauses and obtaining required certified payroll submissions. Questioned costs: $301,011 Identification as a repeat finding: Not applicable. Recommendation: Management should strengthen review and oversight procedures within the A/E Division to ensure all required Federal contract clauses are consistently included in procurements, regardless of dollar threshold, prior to contract execution. This process should include a documented review of the scope of services to identify work of a labor nature and ensure inclusion of applicable Davis-Bacon Act (DBA) provisions where required. Finding No.: 2025-010, continued Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: The finding remains as the condition relates to the support available for review for audit submission that is a draft copy with pending sections without sufficient evidence of effective approval. Management provided response for additional information on June 28, 2026. As we did not have sufficient time to corroborate and examine said additional documentation, our finding remains as there was insufficient evidence to determine compliance at the time of the audit.
Finding No.: 2025-011 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.267 Continuum of Care Program Federal Award No.: GU044L9C002300, GU00377L9C002302, GU0044L9C02300, GU0026L9C002305, GU0011L9C002314 Area: Period of Performance Criteria or specific requirement (including statutory, regulatory or other citation): A recipient may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Conditions: 1. Out of eight expenditures tested totaling $15,536 from a population of $48,657 (out of total expenditures of $1,053,179), four items (50%) were charged to the federal award prior to the start of the approved period of performance. Federal Award No. Payroll Pay period Ended Pay Check date POP Start Date Expenditures Questioned Costs GU0044L9C002300 11/16/24 11/22/24 12/01/24 $1,961 $1,961 GU0044L9C002300 11/02/24 11/08/24 12/01/24 1,697 1,697 GU0044L9C002300 11/02/24 11/08/24 12/01/24 4,072 4,072 GU0044L9C002300 10/19/24 10/25/24 12/01/24 3,455 3,455 $11,185 $11,185 2. Out of 40 manual adjustment transactions tested totaling $56,036 from a population of $218,515 (out of total expenditures of $1,053,179), three items (8%) were manually transferred and charged to the federal award prior to the start of the approved period of performance. Federal Award No. Payroll Pay period Ended Pay Check date POP Start Date Expenditures Questioned Costs GU0037L9C002302 10/19/24 10/25/24 01/01/25 $ 54 $ 54 GU0044L9C002300 11/16/24 11/22/24 12/01/24 824 824 GU0044L9C002300 10/05/24 10/11/24 12/01/24 2,917 2,917 $3,795 $3,795 Finding No.: 2025-011, continued Conditions, continued: 3. Out of 40 manual adjustment transactions tested totaling $56,036 from a population of $218,515 (out of total expenditures of $1,053,179), one item (3%) was manually transferred and charged to a federal award after the approved period of performance ended: Federal Award No. Payroll Pay period Ended Pay Check date POP End Date Expenditures Questioned Costs GU0011L9C002314 10/16/24 08/01/25 09/30/23 $ 837 $ 837 $ 837 $ 837 4. Out of 38 transactions tested totaling $294,156 from a population of $493,625 (out of total expenditures of $1,053,179), one item (3%) was charged to the federal award after the approved period of performance. Federal Award No. Payroll Pay period Ended Pay Check date POP End Date Expenditures Questioned Costs GU0026L9C002305 06/14/25 06/20/25 12/31/24 $ 43 $ 43 $ 43 $ 43 Cause: The GHURA Community Planning Division did not implement adequate monitoring controls to ensure compliance with period of performance requirements. GHURA’s internal control policies and procedures are not sufficiently designed to ensure the timely reclassification and liquidation of obligations within the budget period. Effect or potential effect: GHURA is in noncompliance with applicable period of performance requirements. Questioned costs: $15,860 Identification as a repeat finding: Not applicable. Finding No.: 2025-011, continued Recommendation: Responsible personnel should enforce monitoring controls to ensure compliance with period of performance requirements. The GHURA Community Planning Division should implement formal controls, including standardized timelines and a tracking system for payroll reclassifications and expenditure processing, to prevent the accumulation of unprocessed reimbursements. Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: The finding is sustained as the condition existed during the audit period and was only corrected after management identified the issue completed the corrective reclassification in the subsequent fiscal year.
Finding No.: 2025-012 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.267 Continuum of Care Program Federal Award No.: GU0018L9C002209, GU0026L9C002305, GU0028L9C002204, GU0037L9C002201, GU0031L9C002203 Area: Procurement and Suspension and Debarment Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.214 states: Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. 2 CFR 200.318(h) states: (h) Responsible contractors. The recipient or subrecipient must award contracts only to responsible contractors that possess the ability to perform successfully under the terms and conditions of a proposed contract. The recipient or subrecipient must consider contractor integrity, public policy compliance, proper classification of employees (see the Fair Labor Standards Act, 29 U.S.C. 201, chapter 8), past performance record, and financial and technical resources when conducting a procurement transaction. Condition: Of seven items tested, totaling $288,950 out of $1,053,179 in expenditures subject to suspension and debarment testing, five subawards (71%) lacked evidence of the required verification, as follows: Item # Federal Award No. Vendor No. Expenditures Questioned Costs 1 GU0018L9C002209 LL00000078 $ 40,015 $ 40,015 2 GU0026L9C002305 LL00000078 43,917 43,917 3 GU0028L9C002204 VN000HAPP 118,418 118,418 4 GU0037L9C002201 VN00092963 59,368 59,368 5 GU0031L9C002203 VN00200326 27,232 27,232 $288,950 $288,950 Finding No.: 2025-012, continued Cause: Management has not established formal procedures or documented guidelines requiring verification of vendor suspension/debarment status as part of the awarding process. Effect or potential effect: GHURA is in noncompliance with applicable suspension and debarment requirements. Questioned costs: $288,950 Identification as a repeat finding: Not applicable. Recommendation: Responsible management should establish and consistently enforce formal procedures requiring the retention of all subaward-related documentation, including documented verification of entity eligibility (e.g., SAM.gov checks) and applicable certifications, within the subrecipient file. Views of Responsible Officials: Management concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan.
Finding No.: 2025-013 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.267 Continuum of Care Program Federal Award No.: GU0011L9C002112, GU0011L9C002213, GU0031L9C002203, GU0037L9C002302 Area: Matching, Level of Effort, and Earmarking Criteria or specific requirement (including statutory, regulatory or other citation): The recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. For CoC geographic areas in which there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Condition: Of five grant awards tested, aggregating $569,741 of $ 1,053,179 of expenditures subjected to matching and level of effort tests, three subawards (60%) did not evidence matching of awards from allowable sources as follows: Item No. Grant Award Award Amount FY25 Grant Expenditures Grant Match Requirement Match Amounts Amounts Excess (Short) Questioned Costs 1 GU0011L9C002112 $576,510 $1,762 $144,128 $89,109 $(55,019) $1,762 2 GU0011L9C002213 576,510 6,359 144,128 - (144,128) 6,359 3 GU0037L9C002302 211,987 91,364 22,841 - (22,841) 91,364 Total Questioned Costs $99,485 Cause: Management has not fully implemented formalized policies and procedures to ensure centralized tracking, periodic reconciliation, and supervisory review of matching contributions in accordance with established control expectations. Responsibilities for monitoring matching activity are decentralized with each planner. A periodic management review of cumulative matching, supporting documentation, and source allowability is not consistently performed. Effect or potential effect: GHURA is in noncompliance with applicable matching and level of effort requirements. Questioned costs: $99,485 Finding No.: 2025-013, continued Identification as a repeat finding: Not applicable. Recommendation: Management should establish and implement formal policies and procedures to ensure centralized tracking, timely submission, and periodic reconciliation of matching contributions. Views of Responsible Officials: Management concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan.
Finding No.: 2025-014 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.850 Public Housing Operating Fund Federal Award No.: GQ00100000125D, GQ00100000225D, GQ00100000325D, GQ00100000425D Area: Eligibility Criteria or specific requirement (including statutory, regulatory or other citation): 24 CFR 5.905(a)(1) states: A PHA that administers a Section 8 or public housing program under an Annual Contributions Contract with HUD must carry out background checks necessary to determine whether a member of a household applying for admission to any federally assisted housing program is subject to a lifetime sex offender registration requirement under a State sex offender registration program. This check must be carried out with respect to the State in which the housing is located and with respect to States where members of the applicant household are known to have resided. Section 9 I.E, Other Considerations – Criminal Background Checks, of GHURA Admissions and Continued Occupancy Policy (ACOP) states: Each household member age 18 and over will be required to execute a consent form for a criminal background check as part of the annual reexamination process. Additionally, HUD recommends that at annual reexaminations PHAs ask whether the tenant, or any member of the tenant’s household, is subject to a lifetime sex offender registration requirement in any state [Notice PIH 2012-28]. At the annual reexamination, the PHA will ask whether the tenant, or any member of the tenant’s household, is subject to a lifetime sex offender registration requirement in any state. The PHA will use the Dru Sjodin National Sex Offender database to verify the information provided by the tenant. Finding No.: 2025-014, continued Criteria or specific requirement (including statutory, regulatory or other citation), continued: Section 3‑II.E, EIV System Searches – EIV Income Report of GHURA Admissions and Continued Occupancy Policy (ACOP) states: For each new admission, the PHA is required to review income information in EIV to confirm and validate family reported income within 120 days after the move-in information is transmitted to HUD. The PHA must print and maintain copies of the reports in the tenant file and resolve any discrepancies with the family EIV Income Report. Section 7-I.E. Level 5 and 6 Verifications: Up-Front Income Verification (UIV) of GHURA Admissions and Continued Occupancy Policy (ACOP) states: PHAs are required to obtain an EIV Income report for each family anytime the PHA conducts an annual reexamination. However, PHAs are not required to use the EIV Income report: • At annual reexamination if the PHA used Safe Harbor verification from another means-test federal assistance program to determine the family’s income; or • During any interim reexaminations. The EIV Income Report is also not available for program applicants at admission. When required to use the EIV Income Report, in order for the report to be considered current, the PHA must pull the report within 120 days of the effective date of the annual reexamination. 24 CFR 5.618(b), Acceptable documentation; confidentiality, states: (i) A PHA or owner may determine the net assets of a family based on a certification by the family that the net family assets (as defined in § 5.603) do not exceed $50,000, which amount will be adjusted annually in accordance with the Consumer Price Index for Urban Wage Earners and Clerical Workers, without taking additional steps to verify the accuracy of the declaration. The declaration must state the amount of income the family expects to receive from such assets; this amount must be included in the family's income. (ii) A PHA or owner may determine compliance with paragraph (a)(1)(ii) of this section based on a certification by a family that certifies that such family does not have any present ownership interest in any real property at the time of the income determination or review. Finding No.: 2025-014, continued Criteria or specific requirement (including statutory, regulatory or other citation), continued: Section 7 I.F. of GHURA’s Admissions and Continued Occupancy Policy (ACOP) states: When HUD requires third-party verification, self-certification, or “tenant declaration,” is used as a last resort when the PHA is unable to obtain third-party verification. Self-certification, however, is an acceptable form of verification when: 1. A source of income is fully excluded 2. Net family assets total $5,000 or less and the PHA has adopted a policy to accept self-certification at annual recertification, when applicable 3. The PHA has adopted a policy to implement streamlined annual recertifications for fixed sources of income 24 CFR 5.508(b)(2-3), Evidence of citizenship or eligible immigration status, states: For noncitizens who are 62 years of age or older or who will be 62 years of age or older and receiving assistance under a Section 214 covered program on September 30, 1996 or applying for assistance on or after that date, the evidence consists of: (i) A signed declaration of eligible immigration status; and (ii) Proof of age document For all other noncitizens, the evidence consists of: (i) A signed declaration of eligible immigration status; (ii) One of the INS documents referred to in § 5.510; and (iii) A signed verification consent form. 24 CFR 960.259(c)(1), PHA responsibility for reexamination and verification, states: Except as provided in paragraph (c)(2) of this section, the PHA must obtain and document in the family file third-party verification of the following factors, or must document in the file why third-party verification was not available: (i) Reported family annual income; (ii) The value of assets; (iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income or income-based rent 24 CFR 960.253(b) requires Public Housing Agencies (PHAs) to accurately calculate tenant rent by applying the appropriate rent formula based on verified family income and ensuring the tenant’s rent share is correctly determined in accordance with HUD requirements. Finding No.: 2025-014, continued Criteria or specific requirement (including statutory, regulatory or other citation), continued: 24 CFR 908.101 requires PHAs to maintain complete, accurate, and current records to comply with HUD requirements. Specifically, PHAs must retain complete and accurate data for the most recent three years, including the HUD 50058 (Family Report) and all supporting documentation. 2 CFR 200.303 requires the implementation and monitoring of effective internal controls to provide reasonable assurance that data reported to HUD is accurate, complete, and compliant with Federal requirements. Condition: For thirteen (33%) of forty participants tested, deficiencies were noted, as follows: Item No. Unit Certification Effective Date Criminal History/Sex Offender Registry Search Enterprise Income Verification (EIV) Report Date Other Required PHA Forms Variance (HUD-50058 - Tenant Register) Utility Allowance Variance (HUD-50058 - Register) 1 ALC 05/01/25 Not in file - - - - 2 LTJ 02/01/25 Not in file - - - - 3 EM 09/01/25 10/18/25 - - - - 4 GMM 05/22/25 - 03/19/26 - - - 5 MJA 10/16/24 - 05/30/25 - - - 6 POD 08/27/25 - Not In File - - - 7 SS 08/01/25 - - D-214 Form - - 8 SB 11/01/24 - 09/03/24 D-214 Form - - 9 KL 04/01/25 - 12/10/24 - - - 10 YR 06/01/24 - 05/04/24 - - - 11 SJL 07/01/25 - 04/04/25 - 36 - 12 GJA 07/01/25 - 03/11/25 - (151) 151 13 RJ 04/01/25 Not signed Not signed Self-certification of Assets 49 (210) Finding No.: 2025-014, continued Condition, continued: For item #s 1 and 2, no documentation was on file (e.g. sexual registry clearance form) to support if the PHA verified for lifetime sex offender registration requirements. For item # 3, eligibility determinations were not adequately supported, as the required sex offender checks was not conducted at annual reexamination. For item # 13, the sexual registry clearance form was not certified by the PHA, resulting in insufficient support for eligibility determination. For item #s 4 and 5, the newly admitted participants’ Enterprise Income Verification (EIV) report used to support income eligibility was not processed within 120 days after move in. For item # 6, no documentation was on file to support that the PHA processed the participant’s EIV report. For item # 13, the participant’s EIV report was not certified by the PHA, resulting in insufficient support for income eligibility determination. For item #s 7 and 13, documentation indicating verification of assets (e.g. self-certification forms, tenant declaration, and third-party bank statements) were not on file to support eligibility determination. For item #s 8 and 9, no documentation (e.g. declaration of eligible immigration status form) was on file to support whether non-citizen household members are eligible to receive housing assistance. For item #s 10 through 13, discrepancies which affect eligibility determination and assistance amounts were identified. For item # 10, the tenant rent amount that was agreed to and documented in the lease agreement was lower than the amount calculated by the PHA before annual recertification. For item #s 11 through 13, independently calculated tenant rent and utility allowance amounts differed from the amounts recorded in the PHA’s system and received by participants. Finding No.: 2025-014, continued Condition, continued: For item # 13, the participant’s verified income was understated by the PHA when determining eligibility and calculating housing assistance amounts. Cause: GHURA did not effectively implement monitoring controls to ensure compliance with applicable eligibility requirements. Effect or potential effect: GHURA is in noncompliance with applicable eligibility requirements. Questioned costs: $0 Identification as a repeat finding: Not applicable. Recommendation: Responsible personnel should enforce monitoring controls over compliance with applicable eligibility requirements. Specifically, procedures should be enforced requiring staff to obtain and properly document all required verification documentation prior to the recertification of benefits. In addition, supervisory personnel should perform periodic reviews to verify that these procedures are consistently followed and that all required verification activities have been completed and properly documented. Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.
Finding No.: 2025-015 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.850 Public Housing Operating Fund Federal Award No.: GQ00100000125D, GQ00100000225D, GQ00100000325D, GQ00100000425D Area: Procurement and Suspension and Debarment Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.214 states: Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. GHURA Procurement Policy, Chapter VII further states: For all purchases above the Petty Cash/Micro Purchase threshold, GHURA shall prepare an Independent Cost Estimate (ICE) prior to solicitation. The level of detail shall be commensurate with the cost and complexity of the item to be purchased. 2 CFR 200.319(a) states: All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320. GHURA Procurement Policy, Chapter IV, Sealed Bids, Section D further states: Noncompetitive–contracts: If only one responsive bid is received from a responsible bidder, award shall not be made unless the price can be determined to be reasonable, based on a cost or price analysis and that GHURA obtains HUD approval for contracts exceeding the Simplified Acquisition Threshold or the GHURA's small purchase limit, whichever is less. Finding No.: 2025-015, continued Condition: For twenty-one (72%) of twenty-nine items examined, aggregating $236,001 of $1,508,875, in total expenditures of $1,543,721 subjected to procurement, suspension and debarment tests, deficiencies were noted, as follows: Item # Project No. Purchase Order No. Expenditures Questioned Costs 1 GQ001000003 PO250839 $ 55,700 $ 55,700 2 GQ001000001 PO250018 46,020 46,020 3 GQ001000002 PO250047 33,600 33,600 4 GQ001000001, GQ001000002 GQ001000003, GQ001000004 PO250373 26,371 26,371 5 GQ001000001 PO251763 12,316 12,316 6 GQ001000003 PO251249 2,761 2,761 7 GQ001000002 PO251207 2,730 2,730 8 GQ001000004 PO250955 2,562 2,562 9 GQ001000004 PO250153 2,365 2,365 10 GQ001000003 PO250104 2,123 2,123 11 GQ001000004 PO250572 1,230 1,230 12 GQ001000004 PO250156 1,100 1,100 13 GQ001000002 PO250111 914 914 14 GQ001000002 PO251224 672 672 15 GQ001000004 PO251679 651 651 16 GQ001000002 PO250753 560 560 17 GQ001000004 PO251266 542 542 18 GQ001000004 BPA250133 7,240 7,240 19 GQ001000002 BPA250008 3,500 3,500 20 GQ001000003 BPA250203 3,333 3,333 21 GQ001000002 BPA250025 500 500 $ 206,790 $ 206,790 For item #s 1 through 4, there was no documentation on file to support that GHURA performed procedures to ensure contracting parties are not debarred, suspended, or excluded from receiving or participating in federal awards. For item #s 1 through 21, there was no documentation on file to support that GHURA performed Independent Cost Estimate (ICE) procedures prior to solicitation. For item # 8, there was no documentation on file to support that GHURA conducted the continued procurement of services beyond the contract extension in a manner that ensured adequate competition or proper justification. Finding No.: 2025-015, continued Condition, continued: For item # 16 and item #s 20 and 21, there was no documentation (e.g. solicitations) on file to support the procurement transactions being conducted in a manner that provided for full and open competition. Specifically, there was no evidence of solicitations being issued or documentation on file to justify the use of noncompetitive procurement. For item #s 19 through 21, there was no documentation (e.g. solicitations) on file to support the procurement transactions being conducted in a manner that provided for full and open competition. Specifically, the procurement file lacks evidence of minimum solicitation to support fair competition and does not demonstrate that blanket purchase orders for towing and advertisement services were awarded equally among multiple vendors. Cause: GHURA did not have adequate monitoring controls in place to ensure compliance with applicable procurement, suspension and debarment requirements. Specifically, policies and procedures were not established or enforced to ensure verification and documentation that contracting parties were not suspended or debarred. In addition, procurement personnel did not follow required policies and procedures requiring minimum solicitation and justification for noncompetitive procurement, and management review did not detect or prevent these deficiencies. Effect or potential effect: GHURA is in noncompliance with applicable procurement, suspension and debarment requirements. Questioned costs: $206,790 Recommendation: 1. Responsible management should establish and consistently enforce formal procedures requiring the retention of documented verification of eligibility (e.g., SAM.gov checks) and applicable certifications within the procurement file. Additionally, management should ensure that, prior to the execution of contracts, all agreements include the required suspension and debarment clause to demonstrate compliance with suspension and debarment requirements. 2. Establish controls to ensure required documentation (Independent Cost Estimates, proper justification, etc.) is prepared, documented, and maintained in the procurement file prior to solicitation for all applicable procurements. Finding No.: 2025-015, continued Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.
Finding No.: 2025-016 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.850 Public Housing Operating Fund Federal Award No.: GQ00100000125D, GQ00100000225D, GQ00100000325D, GQ00100000425D Area: Special Tests and Provisions – UEL (Utility Expense Level) Formula Criteria or specific requirement (including statutory, regulatory or other citation): GHURA is required to maintain and annually submit the Utility Expense Level (UEL) Formula Report (HUD Form 52722) for each project to HUD. 24 CFR 990.170(f)(1) states: 1. Appropriate utility records, satisfactory to HUD, shall be developed and maintained, so that consumption and rate data can be determined. 2 CFR 200.303 requires the implementation and monitoring of effective internal controls to provide reasonable assurance that data reported to HUD is accurate, complete, and compliant with Federal requirements. Condition: We examined the 4 reports required to be submitted during the fiscal year. For eight (14%) of total 56 key line reporting items required for testing within the Utility Expense Level (UEL) Formula Report (HUD Form 52722), the amounts were inconsistent from prior audited report submissions as follows: Item No. Project Line No. Utility Expense Level Formula Reported Utilities Reported Amount Per Audited Submission Variance Over (Under) Reported Variance Over (Under) Reported (%) 1 GQ001000001 03 Water and Sewer (Gal) 8,874 8,035 839 9% 2 GQ001000001 04 Water and Sewer (Gal) 5,647 6,486 (839) 15% 3 GQ001000002 03 Water and Sewer (Gal) 410,885 374,845 36,040 9% 4 GQ001000002 04 Water and Sewer (Gal) 383,707 419,747 (36,040) 9% 5 GQ001000003 03 Water and Sewer (Gal) 1,824,296 1,671,242 153,054 8% 6 GQ001000003 04 Water and Sewer (Gal) 2,719,307 2,872,361 (153,054) 6% 7 GQ001000003 03 Water and Sewer (Gal) 3,585,789 3,094,259 491,530 14% 8 GQ001000004 04 Water and Sewer (Gal) 2,663,490 3,155,020 (491,530) 18% Finding No.: 2025-016, continued Condition, continued: For items #s 1 and 2, the Asset Management Project (AMP) 1 reported in excess of amounts for key line items in Rolling base year 2 - actual consumption (12- month period 7/1/2021 to 6/30/2022) for water and sewer gallon consumption, and underreported for Rolling base year 3 - actual consumption (12-month period 7/1/2020 to 6/30/2021) for water gallon consumption than prior year amounts as reported on HUD Form 5722, respectively. For items #s 2 through 4, the Asset Management Project (AMP) 2 reported in excess of amounts for key line items in Rolling base year 2 - actual consumption (12- month period 7/1/2021 to 6/30/2022) for water and sewer gallon consumption, and underreported for Rolling base year 3 - actual consumption (12-month period 7/1/2020 to 6/30/2021) for water gallon consumption than prior year amounts as reported on HUD Form 5722, respectively. For items #s 3 through 6, the Asset Management Project (AMP) 3 reported in excess of amounts for key line items in Rolling base year 2 - actual consumption (12- month period 7/1/2021 to 6/30/2022) for water and sewer gallon consumption, and underreported for Rolling base year 3 - actual consumption (12-month period 7/1/2020 to 6/30/2021) for water gallon consumption than prior year amounts as reported on HUD Form 5722, respectively. For items #$ 7 and 8, the Asset Management Project (AMP) 4 reported in excess of amounts for key line items in Rolling base year 2 - actual consumption (12- month period 7/1/2021 to 6/30/2022) for water and sewer gallon consumption, and underreported for Rolling base year 3 - actual consumption (12-month period 7/1/2020 to 6/30/2021) for water gallon consumption than prior year amounts as reported on HUD Form 5722, respectively. Cause: Management did not implement adequate procedures to agree corrections on the Utility Expense Level (UEL) reporting submissions with underlying utility consumption and cost records prior to submission to HUD. In addition, supervisory review procedures were not sufficient to identify discrepancies, omissions, or reporting-period errors in the data accumulated for UEL reporting purposes. Effect or potential effect: GHURA is in noncompliance with applicable special tests and provisions for UEL Formula requirements. Questioned costs: $0 Finding No.: 2025-016, continued Identification as a repeat finding: Not applicable. Recommendation: Management should implement formal procedures to reconcile UEL reporting submissions to underlying utility consumption and cost records prior to submission to HUD. This should include preparing documented roll-forward reconciliations that ensure current-year reported amounts agree with prior submissions and are accurately carried forward. In addition, management should strengthen supervisory review controls by requiring an independent review of compiled UEL data to verify completeness, accuracy, and proper reporting period classification, with evidence of review retained. Views of Responsible Officials: Management did not provide a response to the finding. The finding was not included in management’s corrective action plan.