Corrective Action Plan: The NCHA has implemented enhanced financial management procedures to ensure the proper segregation of Public Housing and Housing Choice Voucher program funds and prevent the use of one program’s resources to support another program’s expenditures without appropriate authoriza...
Corrective Action Plan: The NCHA has implemented enhanced financial management procedures to ensure the proper segregation of Public Housing and Housing Choice Voucher program funds and prevent the use of one program’s resources to support another program’s expenditures without appropriate authorization, documentation, and accounting treatment. Interprogram transactions are now recorded through established due to/due from accounts and reconciled monthly to ensure accurate fund accountability. Financial policies and procedures have been updated to reinforce program-specific allowable uses of funds, and Finance staff have received training on HUD financial management requirements, fund segregation, and proper accounting practices. Ongoing monthly financial reviews by management will provide continued oversight and ensure compliance with HUD requirements. 1. Program Fund Segregation and Accounting Controls The NCHA has revised its accounting procedures to ensure that all program revenues and expenditures are recorded within the appropriate program fund and cost center. Public Housing Operating Funds will only be utilized for eligible Public Housing activities, and HCV program costs will be supported through HCV Administrative Fees, HCV reserves, or other allowable funding sources. Any transactions identified as requiring temporary interprogram support will be recorded through appropriate due to/due from accounts and will not be treated as program expenditures. Interprogram balances will be tracked separately from operating activity and monitored for timely repayment or resolution. 2. Review and Correction of Historical Transactions Finance staff has completed a review of interprogram transactions to identify instances where costs were charged to the incorrect program. Necessary accounting adjustments have been processed to properly allocate expenditure to the appropriate funding source. Going forward, all program cost allocations will be reviewed to confirm that expenses are: Reasonable and allowable under applicable HUD requirements; Charged of the appropriate program; Supported by adequate documentation; and Consistent with approved cost allocation methodologies. 3. Updated Financial Policies and Procedures The Authority has updated its financial procedures to reinforce: Program-specific expenditure requirements; Prohibited uses of Public Housing funds for HCV activities; Proper recording of interprogram receivables and payables; Required approval and documentation for interprogram transactions; and Monthly reconciliation requirements. The updated procedures establish clear responsibilities for Finance staff, program managers, and supervisory personnel involved in financial review and approval processes. 4. Staff Training and Awareness Finance and program staff have received training regarding: HUD program fund restrictions; Public Housing Operating Fund eligible uses; HCV Administrative Fee limitations; Proper accounting treatment of interprogram activity; and Documentation requirements under federal financial management standards. Additional training will be provided as needed to reinforce compliance and prevent recurrence. 5. Ongoing Monitoring and Quality Control The Finance Director will conduct monthly financial reviews to verify: Public Housing and HCV funds remain properly segregated; Due to/due from balances are accurately recorded and reconciled; Program expenditures are charged to the appropriate funding source; and Corrective actions remain effective. Management will review monthly financial reports, including program-level income statements, balance sheets, and interprogram activity reports, to identify and address potential compliance issues in a timely manner. As part of the corrective action, the NCHA executed an Agreement with BDO to provide financial management training, technical assistance, and workflow support related to HUD program accounting requirements, fund segregation, and proper recording of interprogram activity. BDO assisted Finance staff with strengthening accounting processes, including the development and implementation of standardized Yardi workflows to ensure program-specific coding, proper cost allocation, approval routing, and accurate financial reporting. Responsible Official: CFO, Sr. Staff Accountant with oversight by Executive Director Expected Completion Date: Implemented July 31, 2026; ongoing monitoring and reconciliation