2023-001 Reporting – Late REAC Submission and Late OMB Data Collection Form Submission
Section 8 Housing Voucher Cluster (Section 8):
14.871 Section 8 – Housing Choice Vouchers
Material Weakness in Internal Control, Material Noncompliance
Condition: The Authority’s audited Financial Data Schedule...
2023-001 Reporting – Late REAC Submission and Late OMB Data Collection Form Submission
Section 8 Housing Voucher Cluster (Section 8):
14.871 Section 8 – Housing Choice Vouchers
Material Weakness in Internal Control, Material Noncompliance
Condition: The Authority’s audited Financial Data Schedule (“FDS”) filing was not submitted within the timeframes specified by HUD. The FDS filing was due by June 30, 2024, but the financials were not issued until June 3, 2025. The Authority was also required to submit the OMB Data Collection Form to the Federal Audit Clearinghouse (“FAC”) by June 30, 2024, but was not filed timely as the audit was completed on June 3, 2025.
Recommendation: The Authority should ensure that they retain support for all required documentation and that it is organized and readily accessible. Storing documents electronically with frequent backups would help prevent loss of data from damage to any one location. Furthermore, the Authority should ensure that staff receives necessary training for proper document retention.
Action Taken: To address the identified deficiencies and restore compliance with HUD requirements and the Trouble Recovery Agreement, the Authority will implement the following corrective actions:
1. Leadership and Governance Stabilization: Ensure that the new CEO is briefed on all relevant programs, financial updates, management, and strategic planning initiatives. Ensure that the Finance Committee, within the Board of Commissioners, continues to hold monthly meetings before all regular board meetings and monitors financial reporting, budget adherence, and audit readiness. Ensure that the Administrative Plan for the HCV Program is comprehensively updated to reflect current HUD regulations and strategies for program optimization.
2. Financial Staffing and Capacity Building: Maintain continuity in financial leadership by supporting the Interim CFO and ensuring adequate staffing, such as the new Staff Accountant in the Finance Department, to support audit preparation and HUD reporting. Develop a financial onboarding and training program for all new finance staff, with a focus on HUD systems (FDS, VMS, EPIC, LOCCS) and internal budget protocols. Ensure that Program and Finance Management staff of the HCV Program attend the HCV Financial Management and HCV Financial Accounting and Reporting sessions.
3. Budget Training and Accountability: Implement mandatory budget training for the Finance Department and the HCV Program Department, covering: Budget development and forecasting; Budget-to-actual variance analysis; HUD funding streams and eligible uses; Internal budget controls and documentation standards; Voucher Management System, FDS policies, and SOPs. Create an Accountability Chart for the Program and Financial Management of the HCV Program, outlining roles, responsibilities, and procedures for budget planning, monitoring, and reporting. Require monthly or biweekly meetings with budget reviews by department heads and mid-level managers, with variance explanations submitted to the CFO and CEO, and shared with the Board.
4. Fee Accountant Reinstatement and Optimize HCV Program Finances: Reinstate and formalize the partnership with BDO PHA Finance to support audit preparation, financial reporting, and staff training. Establish financial performance tracking, standard operating procedures (SOPs), contract compliance monitoring, and payment authorization protocols.
5. Technology and Data Management Improvements: Prepare the Chart of Accounts, Procure to Pay, and Voucher Management System (VMS), as well as the Two-Year Tool (TYT), and take other necessary financial steps to ensure a seamless transition from SACS to Reframe. Implement cloud-based storage and digital backup protocols to safeguard financial records and ensure continuity in the event of future disruptions. Establish a centralized digital archive for all financial documents, including budgets, invoices, contracts, and audit work papers.
6. Audit Readiness and Compliance Monitoring: Create an annual audit preparation calendar with clear deadlines for data collection, reconciliations, and internal reviews. Conduct monthly and quarterly internal audits to assess financial controls, procurement compliance, and budget adherence. Submit monthly and quarterly progress reports to HUD and the Board as part of the Troubled Recovery Agreement and internal HUD Recovery Strategic Plan, documenting improvements in financial management and audit readiness.
7. Transparency and Communication: Present monthly financial reports to the Board of Commissioners, including budget-to-actual comparisons and audit status updates. Publish an annual financial summary on the Authority’s website to promote transparency and public accountability