In evaluating appropriate corrective action, management separately considered the audited and the unaudited submissions to the HUD REAC system. While the internal controls over these submissions are very similar, differing circumstances affect future corrective actions.
Audited Submissions - With re...
In evaluating appropriate corrective action, management separately considered the audited and the unaudited submissions to the HUD REAC system. While the internal controls over these submissions are very similar, differing circumstances affect future corrective actions.
Audited Submissions - With respect to the audited submissions, we believe that corrective action was already sufficiently taken during FY24. We note that this finding is a repeat finding from 2023; the focus of that finding was the untimely submission of the 2021 and 2022 submissions. In response to that finding, management increased oversight over the REAC process and engaged an outside CPA firm to provide technical assistance that would increase the speed and accuracy of the submission process. However, the 2023 audit was not completed until July 2024, which was already past the deadline for the 2023 audited submission. Because the audit’s completion is a prerequisite to the audited REAC submission, the delays to the audit’s completion precluded timely submission of the 2023 audited
information. We agree with the auditor’s assessment of a state of noncompliance, as this was the only audited submission required to be made during fiscal year 2024. However, we note that no audited submissions have been required to be made since that time, and as such, no additional corrective action has been implemented since the 2023 audit and the corrective action contemplated in that audit’s corrective action plan.
Unaudited Submissions - With respect to the unaudited submission, management believes that the submissions were untimely not because of a deficiency in internal control but rather a purposeful delay as a matter of practice. BVCOG has, for several years, held off submitting each year’s unaudited data until after the acceptance of the prior year’s audited submission. This was historically done to help ensure that amounts between REAC, VMS, and BVCOG’s financial system reconciled as closely as possible, and that HUD’s acceptance comments on the audited submission were implemented in the very next submission. BVCOG has not received communication from the granting agency with respect to this practice. However, BVCOG recognizes the importance of regulatory deadlines, and in future years, BVCOG will proceed with the submission of the unaudited information regardless of whether or not a previous year’s audited submission is not yet approved by HUD. We will modify our practices accordingly to ensure that HUD comments on any submission are addressed as timely as possible, with a resubmission when necessary.