Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871 & 14.879 Non Compliance - E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 2,320 units. Of a sample size of thirty-four (34) tenant files, the following was noted: HUD form 9886 was unable to be provided in 12 files Verification of income was unable to be provided in 20 files Verification of assets was unable to be provided in 18 files HUD 50058 annual recertification was unable to be provided in 9 files Original Application was unable to be provided in 20 files Citizen Declaration Section 214 form was unable to be provided in 16 files Lead based paint form was unable to be provided in 24 files Signed lease was unable to be provided in 19 files Known Questioned Costs: $104,699* * Represents HAP attributable to twenty (20) tenant files for which the Authority could not demonstrate compliance with eligibility requirements. The questioned costs do not represent amounts determined to be ineligible but rather costs associated with the tenant that remained in noncompliance beyond the required recertification date. Cause: There is a material weakness in internal controls over the eligibility type of compliance related to the maintenance of tenant files in the Housing Voucher Cluster. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Authority is in material non-compliance with the eligibility requirements of the Housing Voucher Cluster programs. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on tenant file maintenance so that documents are accumulated, stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and ProvisionsCriteria: HQS Inspections. Per the Authority's HCV Admin Plan, the PHA must inspect the unit leased to a family biennially in order to determine if the unit meets HQS standards, and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). These inspection reports are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management there were inspection reports that were unavailable for examination at the time of audit. Context: Of a sample size of thirty-four (34) units, twenty-eight (28) units did not have annual HQS inspections performed timely or the Authority was unable to provide proof of inspection. Our sample size is statistically valid. Known Questioned Costs: $186,757* * Represents HAP attributable to twenty-eight (28) tenant files for which the Authority could not demonstrate compliance with HQS requirements. The questioned costs do not represent amounts determined to be ineligible but rather costs associated with the unit that remained in noncompliance beyond the required HQS date. Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly performed HQS inspections in compliance with program requirements. Effect: The Housing Voucher Cluster programs are in material non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on HQS requirements that will reasonably assure compliance with the Uniform Guidance and the compliance supplement.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 & 14.879 Noncompliance – N. Special Tests and Provisions - Housing Assistance Payment Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: PHAs must pay monthly HAP in amounts that agree to Line 12u of the HUD-50058 and are accurately reflected in the HAP contract and HAP register (24 CFR § 982.158 and 24 CFR Part 982, Subpart K). PHAs must adopt and maintain a payment standard schedule establishing voucher payment standards by bedroom size within the PHA’s jurisdiction (24 CFR § 982.505). Payment standards must generally be set within 90 percent to 110 percent of HUD-published Fair Market Rents (FMRs) or Small Area FMRs, as applicable, without HUD approval (24 CFR § 982.503(d)). PHAs are required to review payment standards annually and revise the schedule, as necessary, no later than three months following the effective date of new FMRs to remain within the basic range (24 CFR § 982.503(c)(3)). For new HAP contracts, the payment standard in effect at the time of HAP execution must be used. For existing HAP contracts, increases in payment standards must be applied no later than the earliest of a rent increase affecting the family share, the family’s next regular or interim reexamination, or one year after the effective date of the payment standard increase, unless applied earlier in accordance with the PHA’s Administrative Plan (24 CFR § 982.505(c)(4)). Condition: Based upon inspection of the Authority’s files and on discussion with management, it was determined the Authority applied incorrect payment standard amounts in calculating HAP and were unable to provide the HAP contracts. As a result, the HAP reported on Line 12u of the HUD-50058 were calculated using payment standards that were not applicable to the households at the time the HAP amounts were determined. Context: Of a sample size of thirty-four (34) tenants, twenty-five (25) housing assistance payments contracts were unable to be provided. Of a sample size of thirty-four (34) tenants, twenty (20) tenants' HAP reported on Line 12u of the HUD-50058s were calculated using payment standards that were not applicable to the households at the time of recertification. Our sample size is statistically valid. Criteria: PHAs must pay monthly HAP in amounts that agree to Line 12u of the HUD-50058 and are accurately reflected in the HAP contract and HAP register (24 CFR § 982.158 and 24 CFR Part 982, Subpart K). PHAs must adopt and maintain a payment standard schedule establishing voucher payment standards by bedroom size within the PHA’s jurisdiction (24 CFR § 982.505). Payment standards must generally be set within 90 percent to 110 percent of HUD-published Fair Market Rents (FMRs) or Small Area FMRs, as applicable, without HUD approval (24 CFR § 982.503(d)). PHAs are required to review payment standards annually and revise the schedule, as necessary, no later than three months following the effective date of new FMRs to remain within the basic range (24 CFR § 982.503(c)(3)). For new HAP contracts, the payment standard in effect at the time of HAP execution must be used. For existing HAP contracts, increases in payment standards must be applied no later than the earliest of a rent increase affecting the family share, the family’s next regular or interim reexamination, or one year after the effective date of the payment standard increase, unless applied earlier in accordance with the PHA’s Administrative Plan (24 CFR § 982.505(c)(4)). Condition: Based upon inspection of the Authority’s files and on discussion with management, it was determined the Authority applied incorrect payment standard amounts in calculating HAP and were unable to provide the HAP contracts. As a result, the HAP reported on Line 12u of the HUD-50058 were calculated using payment standards that were not applicable to the households at the time the HAP amounts were determined. Context: Of a sample size of thirty-four (34) tenants, twenty-five (25) housing assistance payments contracts were unable to be provided. Of a sample size of thirty-four (34) tenants, twenty (20) tenants' HAP reported on Line 12u of the HUD-50058s were calculated using payment standards that were not applicable to the households at the time of recertification. Our sample size is statistically valid. Known Questioned Costs: Unknown Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to housing assistance payments. The Authority has not maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster program is in material non-compliance with the special tests and provisions compliance requirement related to the payment standards of housing assistance payments. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to housing assistance payments. The Authority has not maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster program is in material non-compliance with the special tests and provisions compliance requirement related to the payment standards of housing assistance payments. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871 and 14.879 Noncompliance - N. Special Tests and Provisions - Selection from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its Section 8 Administrative Plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203 (Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that certain new move-ins to the Housing Voucher Cluster Programs were selected from the wait list in an order that is in accordance with the Authority’s Section 8 Administrative Plan. Context: Of a sample size of fifteen (15) new move-ins, fifteen (15) could not be determined to be housed in proper order from the Authority's waiting list. Our sample size is statistically valid. Known Questioned Costs: $110,747* * Represents HAP attributable to fifteen (15) new move-ins for which the Authority could not demonstrate compliance with the selection from the waiting list requirements. The questioned costs do not represent amounts determined to be ineligible but rather costs associated with the new move-ins that may not have been housed in compliance with the selection from the waiting list requirements. Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selection from the waiting list. The Authority has not retained records to support proper selection from the waiting list. Effect: The Housing Voucher Program is in material non-compliance with the special tests and provisions type of compliance related to selection from the waiting list. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on properly housing applicants from the Authority's waiting list that will reasonably assure compliance with the Uniform Guidance and the compliance supplement.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871 and 14.879 Noncompliance – N. Special Tests and Provisions - Reasonable Rent Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Reasonable Rent. The Authority must do the following: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority 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 Authority must maintain records to document the basis 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: Based upon inspection of the Authority’s files and discussion with management, there were newly leased units for which the evaluation of rent reasonableness was not performed. Context: There were approximately one hundred fifty-three (153) newly leased units. Of a sample size of fifteen (15) newly leased units, four (4) units' documentation of reasonable rent was not available for examination. Our sample size is statistically valid. Known Questioned Costs: $7,383* * Represents HAP attributable to four (4) new move-ins for which the Authority could not demonstrate compliance with the rent reasonableness requirements. The questioned costs do not represent amounts determined to be ineligible but rather costs associated with the new move-ins that may not have been housed in compliance with the rent reasonableness requirements. Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to reasonable rent. The Authority has not maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Choice Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to reasonable rent. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on performing the appropriate rent reasonableness procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Choice Vouchers Federal Catalog Numbers: 14.871 and 14.879 Noncompliance – N. Special Tests and Provisions – HQS Enforcement Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Enforcement. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussions with management, the Authority was unable to provide support for several failed inspection selections. The Authority was also unable to provide a failed inspections listing for January through May 2025. Context: Of a sample size of twenty-five (25) units the Authority was unable to provide the following: Failed inspections for six (6) units Passed inspections for nineteen (19) units Proof of abatement or extension for two (2) units Known Questioned Costs: $44,299* * Represents HAP attributable to twenty-one (21) failed units for which the Authority could not demonstrate compliance with the HQS enforcement requirements. The questioned costs do not represent amounts determined to be ineligible but rather costs associated with the units that remained in noncompliance beyond the required HQS enforcement date. Cause: There is a material weakness in internal controls over compliance for the special tests and provisions type of compliance related to HQS enforcement. The Authority has not properly performed or kept record of HQS inspections in compliance with program requirements. Effect: The Housing Voucher Cluster Programs are in material non-compliance with the special tests and provisions type of compliance related to HQS enforcement. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on HQS enforcement that will reasonably assure compliance with the Uniform Guidance and the compliance supplement.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Assistance Listing Numbers: 14.850 Material Noncompliance Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance Criteria: The Authority must maintain complete and accurate accounts and other records for the program in accordance with HUD compliance requirements. Condition: The Authority did not maintain complete and accurate accounts and other records in accordance with HUD compliance requirements regarding Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility, Reporting, and Special Tests and Provisions. Context: The Authority was unable to provide requested documentation at the time of audit to properly test the HUD compliance requirements. Known Questioned Costs: Unknown Cause: There is a material weakness in internal controls over compliance related to the maintenance of tenant files, wait lists, inspection reports and other records. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Public and Indian Housing Program is in material non-compliance with the compliance requirements of the program. Recommendation: We recommend that the Authority implement a process whereby Authority documents are stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public Housing Capital Fund Program Federal Assistance Listing Numbers: 14.872 Noncompliance - C. Cash Management Non Compliance Material to the Financial Statements: No Significant deficiency in Internal Control over Compliance for Cash Management Criteria: In accordance with 2 CFR 200.305, payment methods for federal awards must minimize the time elapsing between the transfer of federal funds and the disbursement of those funds by the recipient. Federal funds drawn under the Public Housing Capital Fund Program should be limited to amounts needed to meet the Authority’s immediate cash requirements for allowable program expenditures. Accordingly, the Authority should implement procedures to ensure grant funds are not drawn in advance of actual or imminent eligible expenditures. Condition: The Authority drew down federal funds in advance of immediate cash needs for allowable program expenditures. As of year end, a portion of the funds drawn remained unexpended and was reported as unearned revenue in the financial statements. This indicates that federal funds were received prior to the incurrence of eligible expenditures. Context: During review of the financial statements, the Authority was noted to have unexpended federal funds on hand at year end that had been drawn prior to the disbursement of allowable program costs. Specifically, amounts recorded as unearned revenue represented federal funds received in advance of immediate cash needs. This condition was identified through review of drawdown activity, general ledger balances, and year end financial reporting records. Known Questioned Costs: $465,581 Cause: The Authority did not have adequate internal controls in place to monitor the timing of grant drawdowns in relation to actual program cash needs and allowable expenditures. As a result, federal funds were requested and received prior to the incurrence of eligible costs under the Public Housing Capital Fund Program. Effect: The Authority was not in compliance with federal cash management requirements governing the timing of federal fund drawdowns. As a result, federal funds were held in advance of immediate cash needs, increasing the risk of improper cash management and noncompliance with Uniform Guidance and HUD requirements. Recommendation: We recommend the Authority strengthen its internal controls over cash management to ensure federal funds are drawn only for immediate cash needs related to allowable program expenditures. Management should implement monitoring and review controls over grant drawdown activity, including periodic reconciliation of drawdowns to incurred expenditures, to ensure compliance with 2 CFR 200.305 and HUD requirements.