Audit 6779

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria or specific requirement: The PHA is required to submit the HUD-50058 (Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that PIC submissions requirements were being met. As a result, a submitted HUD-50058 did not match the data submitted to PIC. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for PIC submissions revealed that for 1 file the Commission failed to correct a fatal error after initial submission. As a result, the HUD - 50058 was not showing as reported in PIC. Cause: The Commission could not correct the fatal error because the initial PHA did not complete the Port Out action in PIC. Additionally, the commission was unable to generate a type 14 action, because the initial PHA changed the Head of Household on the submitted HUD 52665 & 50058 forms; the social security numbers changed. The Commission was eventually able to correct the fatal error after continuous outreach to the initial PHA. Effect: The Commission is not in compliance with program requirements over PIC Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors during PIC submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria or specific requirement: The PHA is required to submit the HUD-50058 (Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that PIC submissions requirements were being met. As a result, a submitted HUD-50058 did not match the data submitted to PIC. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for PIC submissions revealed that for 1 file the Commission failed to correct a fatal error after initial submission. As a result, the HUD - 50058 was not showing as reported in PIC. Cause: The Commission could not correct the fatal error because the initial PHA did not complete the Port Out action in PIC. Additionally, the commission was unable to generate a type 14 action, because the initial PHA changed the Head of Household on the submitted HUD 52665 & 50058 forms; the social security numbers changed. The Commission was eventually able to correct the fatal error after continuous outreach to the initial PHA. Effect: The Commission is not in compliance with program requirements over PIC Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors during PIC submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria or specific requirement: The PHA is required to submit the HUD-50058 (Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that PIC submissions requirements were being met. As a result, a submitted HUD-50058 did not match the data submitted to PIC. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for PIC submissions revealed that for 1 file the Commission failed to correct a fatal error after initial submission. As a result, the HUD - 50058 was not showing as reported in PIC. Cause: The Commission could not correct the fatal error because the initial PHA did not complete the Port Out action in PIC. Additionally, the commission was unable to generate a type 14 action, because the initial PHA changed the Head of Household on the submitted HUD 52665 & 50058 forms; the social security numbers changed. The Commission was eventually able to correct the fatal error after continuous outreach to the initial PHA. Effect: The Commission is not in compliance with program requirements over PIC Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors during PIC submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Other Matters. Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) 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)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $38,180 Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 9 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 13 files where the inspection was not completed and passed within regulatory period. Cause: The Commission works with a third-party contractor to conduct all HCV inspections. The contractor did not inspect several units during the COVID pandemic and consequently played catch up this fiscal year. Moreover, the inspection company did not always notify the Commission to place a unit in abatement. As a result, the Commission has hired a new inspection company effective October 1, 2023 to conduct all inspections. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Other Matters. Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) 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)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $38,180 Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 9 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 13 files where the inspection was not completed and passed within regulatory period. Cause: The Commission works with a third-party contractor to conduct all HCV inspections. The contractor did not inspect several units during the COVID pandemic and consequently played catch up this fiscal year. Moreover, the inspection company did not always notify the Commission to place a unit in abatement. As a result, the Commission has hired a new inspection company effective October 1, 2023 to conduct all inspections. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Other Matters. Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) 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)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $38,180 Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 9 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 13 files where the inspection was not completed and passed within regulatory period. Cause: The Commission works with a third-party contractor to conduct all HCV inspections. The contractor did not inspect several units during the COVID pandemic and consequently played catch up this fiscal year. Moreover, the inspection company did not always notify the Commission to place a unit in abatement. As a result, the Commission has hired a new inspection company effective October 1, 2023 to conduct all inspections. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed the following exceptions: - 1 file missing documentation needed to support and recalculate total income per HUD-50059 - 2 files that were missing support needed to substantiate the asset total per HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed the following exceptions: - 1 file missing documentation needed to support and recalculate total income per HUD-50059 - 2 files that were missing support needed to substantiate the asset total per HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 40 HCVP tenant files for annual inspection standards revealed the following exceptions: - 4 files did not have an annual inspection that was completed within the 12-month fiscal period. - 33 files did not have a previous or subsequent inspection performed to verify the Commission is performing inspection on an annual basis. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 40 HCVP tenant files for annual inspection standards revealed the following exceptions: - 4 files did not have an annual inspection that was completed within the 12-month fiscal period. - 33 files did not have a previous or subsequent inspection performed to verify the Commission is performing inspection on an annual basis. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 2 files had the following exceptions: - 1 file failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC. - Management failed to follow up on 1 file due to TRACS creating a termination for late processing of reexamination. Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 2 files had the following exceptions: - 1 file failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC. - Management failed to follow up on 1 file due to TRACS creating a termination for late processing of reexamination. Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: PHA must select participants from the waiting list in accordance with the admission policies in its administrative plan and maintain documentation which shows that, at the time of admission, the family actually met the preference criteria that determined the family’s place on the waiting list. For the Mod Rehab SRO program, eligible individuals may be referred to the PHA for eligibility determination as a result of the owner’s/sponsor’s outreach or through the PHA waiting list (24 CFR sections 880.603, 881.601, 882.514, 882.808(b)(2), 883.701, 884.214, and 886 subparts A and C). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure tenant permanent files contain waiting list documents. As a result, the Commission is unable to support the admission of the tenant in accordance with the admission policies. Questioned costs: Unknown Context: Testing of 6 tenant files for waiting list documentation revealed that: - 1 selection could not be supported by documentation. Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over new admissions to the program. Effect: The Commission is not in compliance with program requirements over the waiting list. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that waiting list documentation is maintained for all tenants. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: PHA must select participants from the waiting list in accordance with the admission policies in its administrative plan and maintain documentation which shows that, at the time of admission, the family actually met the preference criteria that determined the family’s place on the waiting list. For the Mod Rehab SRO program, eligible individuals may be referred to the PHA for eligibility determination as a result of the owner’s/sponsor’s outreach or through the PHA waiting list (24 CFR sections 880.603, 881.601, 882.514, 882.808(b)(2), 883.701, 884.214, and 886 subparts A and C). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure tenant permanent files contain waiting list documents. As a result, the Commission is unable to support the admission of the tenant in accordance with the admission policies. Questioned costs: Unknown Context: Testing of 6 tenant files for waiting list documentation revealed that: - 1 selection could not be supported by documentation. Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over new admissions to the program. Effect: The Commission is not in compliance with program requirements over the waiting list. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that waiting list documentation is maintained for all tenants. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria or specific requirement: The PHA is required to submit the HUD-50058 (Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that PIC submissions requirements were being met. As a result, a submitted HUD-50058 did not match the data submitted to PIC. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for PIC submissions revealed that for 1 file the Commission failed to correct a fatal error after initial submission. As a result, the HUD - 50058 was not showing as reported in PIC. Cause: The Commission could not correct the fatal error because the initial PHA did not complete the Port Out action in PIC. Additionally, the commission was unable to generate a type 14 action, because the initial PHA changed the Head of Household on the submitted HUD 52665 & 50058 forms; the social security numbers changed. The Commission was eventually able to correct the fatal error after continuous outreach to the initial PHA. Effect: The Commission is not in compliance with program requirements over PIC Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors during PIC submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria or specific requirement: The PHA is required to submit the HUD-50058 (Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that PIC submissions requirements were being met. As a result, a submitted HUD-50058 did not match the data submitted to PIC. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for PIC submissions revealed that for 1 file the Commission failed to correct a fatal error after initial submission. As a result, the HUD - 50058 was not showing as reported in PIC. Cause: The Commission could not correct the fatal error because the initial PHA did not complete the Port Out action in PIC. Additionally, the commission was unable to generate a type 14 action, because the initial PHA changed the Head of Household on the submitted HUD 52665 & 50058 forms; the social security numbers changed. The Commission was eventually able to correct the fatal error after continuous outreach to the initial PHA. Effect: The Commission is not in compliance with program requirements over PIC Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors during PIC submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria or specific requirement: The PHA is required to submit the HUD-50058 (Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that PIC submissions requirements were being met. As a result, a submitted HUD-50058 did not match the data submitted to PIC. Questioned Costs: Unknown Context: Testing of 40 HCVP tenant files for PIC submissions revealed that for 1 file the Commission failed to correct a fatal error after initial submission. As a result, the HUD - 50058 was not showing as reported in PIC. Cause: The Commission could not correct the fatal error because the initial PHA did not complete the Port Out action in PIC. Additionally, the commission was unable to generate a type 14 action, because the initial PHA changed the Head of Household on the submitted HUD 52665 & 50058 forms; the social security numbers changed. The Commission was eventually able to correct the fatal error after continuous outreach to the initial PHA. Effect: The Commission is not in compliance with program requirements over PIC Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors during PIC submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Other Matters. Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) 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)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $38,180 Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 9 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 13 files where the inspection was not completed and passed within regulatory period. Cause: The Commission works with a third-party contractor to conduct all HCV inspections. The contractor did not inspect several units during the COVID pandemic and consequently played catch up this fiscal year. Moreover, the inspection company did not always notify the Commission to place a unit in abatement. As a result, the Commission has hired a new inspection company effective October 1, 2023 to conduct all inspections. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Other Matters. Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) 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)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $38,180 Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 9 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 13 files where the inspection was not completed and passed within regulatory period. Cause: The Commission works with a third-party contractor to conduct all HCV inspections. The contractor did not inspect several units during the COVID pandemic and consequently played catch up this fiscal year. Moreover, the inspection company did not always notify the Commission to place a unit in abatement. As a result, the Commission has hired a new inspection company effective October 1, 2023 to conduct all inspections. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 / 14.879 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Other Matters. Criteria: PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. (24 CFR sections 982.158(d) and 982.404). PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) 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)). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned Costs: $38,180 Context: Testing of 40 HCVP tenant files for failed inspection standards revealed the following: 9 files where abatement ought to have been implemented, but records could not be located. Testing of 40 HCVP tenant files for annual inspection standards revealed the following: 13 files where the inspection was not completed and passed within regulatory period. Cause: The Commission works with a third-party contractor to conduct all HCV inspections. The contractor did not inspect several units during the COVID pandemic and consequently played catch up this fiscal year. Moreover, the inspection company did not always notify the Commission to place a unit in abatement. As a result, the Commission has hired a new inspection company effective October 1, 2023 to conduct all inspections. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed the following exceptions: - 1 file missing documentation needed to support and recalculate total income per HUD-50059 - 2 files that were missing support needed to substantiate the asset total per HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22-6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: As a condition of admission or continue occupancy, PHA’s must determine eligibility of applicants by (a) obtaining signed applications that contain the information needed to determine eligibility (including designation as elderly, disabled, or homeless, if applicable), income, rent, and order of selection; (b) conducting verifications of family income and other pertinent information (such as assets, full time student and immigration status, and unusual medical expenses) through third parties; (c) documenting inspections and tenant certifications, as appropriate; and, (d) determining that tenant income did not exceed the maximum limit set by HUD for the PHA’s jurisdiction, as shown in HUD’s published notice transmitting the Limits for Low-Income and Very Low-Income Families Under the Housing Act of 1937. For the Mod Rehab SRO program, eligible individuals must be homeless upon entry into the program (24 CFR sections 880.603, 881.601, 882.514, 882.808, 833.701, 884.214, 886.119, and 886.318). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that eligibility requirements were being met. Questioned costs: Unknown Context: Testing of 40 tenant files for eligibility standards revealed the following exceptions: - 1 file missing documentation needed to support and recalculate total income per HUD-50059 - 2 files that were missing support needed to substantiate the asset total per HUD-50059 Cause: The Commission does not have controls in place to ensure it is meeting eligibility requirements set by HUD. Effect: The Commission is not in compliance with program requirements over eligibility. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 40 HCVP tenant files for annual inspection standards revealed the following exceptions: - 4 files did not have an annual inspection that was completed within the 12-month fiscal period. - 33 files did not have a previous or subsequent inspection performed to verify the Commission is performing inspection on an annual basis. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance.  Material Noncompliance (Modified Opinion) Criteria: PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS). The PHA must prepare a unit inspection report (24 CFR sections 880.612, 881.601, 882.516, 882.808(n), 883.701, 884.217, 886.123, and 886.323).). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure that HQS requirements were being met. As a result, inspections were not completed timely or at all. Questioned costs: Unknown Context: Testing of 40 HCVP tenant files for annual inspection standards revealed the following exceptions: - 4 files did not have an annual inspection that was completed within the 12-month fiscal period. - 33 files did not have a previous or subsequent inspection performed to verify the Commission is performing inspection on an annual basis. Cause: The Commission does not have controls in place to ensure it is meeting HQS inspection requirements set by HUD. Effect: The Commission is not in compliance with program requirements over HQS inspections. Repeat Finding: Yes. Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 2 files had the following exceptions: - 1 file failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC. - Management failed to follow up on 1 file due to TRACS creating a termination for late processing of reexamination. Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: The PHA is required to submit the HUD-50058 and HUD-50059(Family Report) form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family to HUD’s Public Housing Information Center (PIC) or the Tenant Rental Assistance Certification Program (TRACS). The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that HUD-50058 and HUD-50059 reporting requirements were being met. As a result, a HUD-50058 and HUD-50059 were not submitted timely. Questioned costs: Unknown Context: Testing of 40 tenant files for special reporting revealed that 2 files had the following exceptions: - 1 file failed to correct a fatal error after initial submission. As a result, the HUD-50058 was not showing as reported in PIC. - Management failed to follow up on 1 file due to TRACS creating a termination for late processing of reexamination. Cause: The Commission does not have internal controls in place to ensure it is meeting TRACS submissions eligibility requirements set by HUD. The Commission failed to correct the fatal error in PIC due to staffing vacancies. Effect: The Commission is not in compliance with program requirements over PIC/TRACS Reporting. Repeat Finding: Not a repeat. Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: PHA must select participants from the waiting list in accordance with the admission policies in its administrative plan and maintain documentation which shows that, at the time of admission, the family actually met the preference criteria that determined the family’s place on the waiting list. For the Mod Rehab SRO program, eligible individuals may be referred to the PHA for eligibility determination as a result of the owner’s/sponsor’s outreach or through the PHA waiting list (24 CFR sections 880.603, 881.601, 882.514, 882.808(b)(2), 883.701, 884.214, and 886 subparts A and C). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure tenant permanent files contain waiting list documents. As a result, the Commission is unable to support the admission of the tenant in accordance with the admission policies. Questioned costs: Unknown Context: Testing of 6 tenant files for waiting list documentation revealed that: - 1 selection could not be supported by documentation. Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over new admissions to the program. Effect: The Commission is not in compliance with program requirements over the waiting list. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that waiting list documentation is maintained for all tenants. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Section 8 Project-Based Cluster Assistance Listing Number: 14.195/14.856 Federal Award Identification Number and Year: MD004 (various funding increments active during period 7/1/22 - 6/30/23) Award Period: July 1, 2022 through June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance.  Other Matters. Criteria: PHA must select participants from the waiting list in accordance with the admission policies in its administrative plan and maintain documentation which shows that, at the time of admission, the family actually met the preference criteria that determined the family’s place on the waiting list. For the Mod Rehab SRO program, eligible individuals may be referred to the PHA for eligibility determination as a result of the owner’s/sponsor’s outreach or through the PHA waiting list (24 CFR sections 880.603, 881.601, 882.514, 882.808(b)(2), 883.701, 884.214, and 886 subparts A and C). Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure tenant permanent files contain waiting list documents. As a result, the Commission is unable to support the admission of the tenant in accordance with the admission policies. Questioned costs: Unknown Context: Testing of 6 tenant files for waiting list documentation revealed that: - 1 selection could not be supported by documentation. Cause: The Commission does not have internal controls in place to ensure it is meeting program requirements over new admissions to the program. Effect: The Commission is not in compliance with program requirements over the waiting list. Repeat Finding: Not a repeat finding. Recommendation: The Commission should implement processes to ensure that waiting list documentation is maintained for all tenants. View of Responsible Officials: There is no disagreement with the audit finding.