Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Public and Indian Housing (Non-major Program) Programs Federal Assistance Listing Number: 14.850 and 14.871 Noncompliance – B. Allowable Costs/Cost Principles Noncompliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Allowable Costs/Cost Principles Criteria: The Authority's federal program expenditures must meet the requirements of 2 CFR Part 200 Subpart E Cost Principles and conflict of interest requirements of 24 CFR 982.161, and must be adequately documented. Condition: Based upon inspection of the Authority’s paid invoices and on discussion with management, there were costs that were determined to be unallowable. Additionally, reimbursements were made to employees in violation of the Authority's adopted personnel policy. There were excessive reimbursements to employees that would be considered outside the normal course of business of the Authority, and housing assistance payments were made to landlords that would be considered a conflict of interest as defined in 24 CFR 982.161. Context: The following costs were determined to be unallowable or not reasonable or necessary in the proper and efficient performance of the federal program: Meals and gifts (2 CFR section 200.438) Alcohol (2 CFR section 200.423) Professional service costs (2 CFR section 200.459) Travel (2 CFR section 200.475) Payments to landlords that represent a conflict of interest (24 CFR 982.161) Known Questioned Costs: $107,736 Cause: There is a significant deficiency in internal controls over the compliance for the allowable costs/cost principles type of compliance requirement. Housing assistance payments were made to landlords that are defined as a conflict of interest, and approval was granted to reimburse Authority personnel without properly considering the allowability of such costs in accordance with 2 CFR 200. Effect: The Public and Indian Housing and Section 8 Housing Choice Vouchers Programs expended federal funds for unallowable items and as such is in non-compliance with the allowable costs/cost principles type of compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. This includes the proper internal control procedures to review invoices in accordance with program requirements, as well as compliance with the Authority's adopted personnel policy. Additionally, the Authority should establish internal controls related to the proper approval of these invoices for payment.
Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Public and Indian Housing (Non-major Program) Programs Federal Assistance Listing Number: 14.850 and 14.871 Noncompliance – B. Allowable Costs/Cost Principles Noncompliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Allowable Costs/Cost Principles Criteria: The Authority's federal program expenditures must meet the requirements of 2 CFR Part 200 Subpart E Cost Principles and conflict of interest requirements of 24 CFR 982.161, and must be adequately documented. Condition: Based upon inspection of the Authority’s paid invoices and on discussion with management, there were costs that were determined to be unallowable. Additionally, reimbursements were made to employees in violation of the Authority's adopted personnel policy. There were excessive reimbursements to employees that would be considered outside the normal course of business of the Authority, and housing assistance payments were made to landlords that would be considered a conflict of interest as defined in 24 CFR 982.161. Context: The following costs were determined to be unallowable or not reasonable or necessary in the proper and efficient performance of the federal program: Meals and gifts (2 CFR section 200.438) Alcohol (2 CFR section 200.423) Professional service costs (2 CFR section 200.459) Travel (2 CFR section 200.475) Payments to landlords that represent a conflict of interest (24 CFR 982.161) Known Questioned Costs: $107,736 Cause: There is a significant deficiency in internal controls over the compliance for the allowable costs/cost principles type of compliance requirement. Housing assistance payments were made to landlords that are defined as a conflict of interest, and approval was granted to reimburse Authority personnel without properly considering the allowability of such costs in accordance with 2 CFR 200. Effect: The Public and Indian Housing and Section 8 Housing Choice Vouchers Programs expended federal funds for unallowable items and as such is in non-compliance with the allowable costs/cost principles type of compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. This includes the proper internal control procedures to review invoices in accordance with program requirements, as well as compliance with the Authority's adopted personnel policy. Additionally, the Authority should establish internal controls related to the proper approval of these invoices for payment.
Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Public and Indian Housing (Non-major Program) Programs Federal Assistance Listing Number: 14.850 and 14.871 Noncompliance – B. Allowable Costs/Cost Principles Noncompliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Allowable Costs/Cost Principles Criteria: The Authority's federal program expenditures must meet the requirements of 2 CFR Part 200 Subpart E Cost Principles and conflict of interest requirements of 24 CFR 982.161, and must be adequately documented. Condition: Based upon inspection of the Authority’s paid invoices and on discussion with management, there were costs that were determined to be unallowable. Additionally, reimbursements were made to employees in violation of the Authority's adopted personnel policy. There were excessive reimbursements to employees that would be considered outside the normal course of business of the Authority, and housing assistance payments were made to landlords that would be considered a conflict of interest as defined in 24 CFR 982.161. Context: The following costs were determined to be unallowable or not reasonable or necessary in the proper and efficient performance of the federal program: Meals and gifts (2 CFR section 200.438) Alcohol (2 CFR section 200.423) Professional service costs (2 CFR section 200.459) Travel (2 CFR section 200.475) Payments to landlords that represent a conflict of interest (24 CFR 982.161) Known Questioned Costs: $107,736 Cause: There is a significant deficiency in internal controls over the compliance for the allowable costs/cost principles type of compliance requirement. Housing assistance payments were made to landlords that are defined as a conflict of interest, and approval was granted to reimburse Authority personnel without properly considering the allowability of such costs in accordance with 2 CFR 200. Effect: The Public and Indian Housing and Section 8 Housing Choice Vouchers Programs expended federal funds for unallowable items and as such is in non-compliance with the allowable costs/cost principles type of compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. This includes the proper internal control procedures to review invoices in accordance with program requirements, as well as compliance with the Authority's adopted personnel policy. Additionally, the Authority should establish internal controls related to the proper approval of these invoices for payment.
Finding 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Public and Indian Housing (Non-major Program) Programs Federal Assistance Listing Number: 14.850 and 14.871 Noncompliance – B. Allowable Costs/Cost Principles Noncompliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Allowable Costs/Cost Principles Criteria: The Authority's federal program expenditures must meet the requirements of 2 CFR Part 200 Subpart E Cost Principles and conflict of interest requirements of 24 CFR 982.161, and must be adequately documented. Condition: Based upon inspection of the Authority’s paid invoices and on discussion with management, there were costs that were determined to be unallowable. Additionally, reimbursements were made to employees in violation of the Authority's adopted personnel policy. There were excessive reimbursements to employees that would be considered outside the normal course of business of the Authority, and housing assistance payments were made to landlords that would be considered a conflict of interest as defined in 24 CFR 982.161. Context: The following costs were determined to be unallowable or not reasonable or necessary in the proper and efficient performance of the federal program: Meals and gifts (2 CFR section 200.438) Alcohol (2 CFR section 200.423) Professional service costs (2 CFR section 200.459) Travel (2 CFR section 200.475) Payments to landlords that represent a conflict of interest (24 CFR 982.161) Known Questioned Costs: $107,736 Cause: There is a significant deficiency in internal controls over the compliance for the allowable costs/cost principles type of compliance requirement. Housing assistance payments were made to landlords that are defined as a conflict of interest, and approval was granted to reimburse Authority personnel without properly considering the allowability of such costs in accordance with 2 CFR 200. Effect: The Public and Indian Housing and Section 8 Housing Choice Vouchers Programs expended federal funds for unallowable items and as such is in non-compliance with the allowable costs/cost principles type of compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. This includes the proper internal control procedures to review invoices in accordance with program requirements, as well as compliance with the Authority's adopted personnel policy. Additionally, the Authority should establish internal controls related to the proper approval of these invoices for payment.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Number: 14.850 Noncompliance – B. Allowable Costs/Cost Principles Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Allowable Costs/Cost Principles Criteria: The Authority's federal program expenditures must meet the requirements of 2 CFR Part 200 Subpart E Cost Principles and must be adequately documented. Condition: Based upon inspection of the Authority’s paid invoices and on discussion with management, there were costs that were determined to be unallowable. Context: The following costs were determined to be unallowable or not reasonable or necessary in the proper and efficient performance of the federal program: Alcoholic beverages (2 CFR section 200.423) Meals (2 CFR section 200.438) Known Questioned Costs: $1,260 Cause: There is a significant deficiency in internal controls over the compliance for the allowable costs/cost principles type of compliance. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance with the allowable costs/cost principles requirements. Effect: The Public and Indian Housing Program is in non-compliance with the allowable costs/cost principles type of compliance. 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: Public and Indian Housing Program Federal Assistance Listing Number: 14.850 Noncompliance – B. Allowable Costs/Cost Principles Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Allowable Costs/Cost Principles Criteria: The Authority's federal program expenditures must meet the requirements of 2 CFR Part 200 Subpart E Cost Principles and must be adequately documented. Condition: Based upon inspection of the Authority’s paid invoices and on discussion with management, there were costs that were determined to be unallowable. Context: The following costs were determined to be unallowable or not reasonable or necessary in the proper and efficient performance of the federal program: Alcoholic beverages (2 CFR section 200.423) Meals (2 CFR section 200.438) Known Questioned Costs: $1,260 Cause: There is a significant deficiency in internal controls over the compliance for the allowable costs/cost principles type of compliance. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance with the allowable costs/cost principles requirements. Effect: The Public and Indian Housing Program is in non-compliance with the allowable costs/cost principles type of compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement.
2023-001: Alcohol Purchased with PHA Funds CFDA Title and Number: Public and Indian Housing - 14.850 Name of Federal Agency: Department of Housing and Urban Development Internal Control Over Compliance: Allowable Costs / Cost Principles Criteria: 2 CFR 200.423 prohibits PHAs from purchasing alcohol using PHA funds. Condition: During our testing, we found two instances of alcohol. Cause: Unknown. Effect or Potential Effect: Noncompliance with Uniform Guidance requirement. Questioned Cost: $18 Repeat of a Prior Year Finding: No Recommendation: We recommend that the PHA establish policies and procedures to ensure that all funds are only spent on allowable costs. PHA’s Response: We will do as recommended. Corrective Action Plan: Not provided. Responsible Person: Executive Director James Nichols Jr.
2023-001: Alcohol Purchased with PHA Funds CFDA Title and Number: Public and Indian Housing - 14.850 Name of Federal Agency: Department of Housing and Urban Development Internal Control Over Compliance: Allowable Costs / Cost Principles Criteria: 2 CFR 200.423 prohibits PHAs from purchasing alcohol using PHA funds. Condition: During our testing, we found two instances of alcohol. Cause: Unknown. Effect or Potential Effect: Noncompliance with Uniform Guidance requirement. Questioned Cost: $18 Repeat of a Prior Year Finding: No Recommendation: We recommend that the PHA establish policies and procedures to ensure that all funds are only spent on allowable costs. PHA’s Response: We will do as recommended. Corrective Action Plan: Not provided. Responsible Person: Executive Director James Nichols Jr.
Finding 2022-001: (21.027) Unallowable Activities/Allowable Costs and Cost Principals Criteria: As specified in Section 2 CFR 200.423, General Provisions for Selected Items of Cost-Alcoholic Beverages, costs of alcoholic beverages are unallowable. Condition: An amount of $329.25 for the purchase of alcoholic beverages was reimbursed to the School with federal funds.. Cause: Certain expenditures were not correctly identified and excluded from reimbursement requests. Effect: The School was not in compliance with award and federal statutes. The School is potentially subject to federal funding cuts or other punitive actions. Recommendation: The School should ensure that expenditures are compiled and reviewed to meet the terms and conditions of the award and federal statutes. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying Management?s Corrective Action Plan.
Type of Finding: • Significant Deficiency in Internal Control over Compliance – Allowable Costs/Cost Principles • Other Matter – Non-Compliance with Allowable Costs/Cost Principles Compliance Requirements Federal Agency: Department of Transportation Federal Program Name: Enhanced Mobility of Seniors and Individuals with Disabilities Assistance Listing Number: 20.513 Federal Award Identification Number and Year: PTD0287-2022 Pass-Through Agency: WADOT Pass-Through Number(s): PTD0287 Award Period: July 1, 2021 through June 30, 2023 Criteria or specific requirement: 2 CFR 200.423 specifically identifies alcoholic beverages as unallowable costs. Condition: CLA noted one sample in which federal funds were expended on unallowable costs. Questioned costs: $85 known, $910 likely Context: A sample of 25 was made from a population of 942 nonpayroll-related general disbursement costs charged to the major program. Of the 25 sampled costs, one was found to be out of compliance with the requirements of Allowable Costs / Cost Principles, totaling $85. Sampled nonpayroll-related general disbursement costs totaled $24,560. General disbursements totaled $263,090 of the $1,706,762 tracked to the major program. Extrapolating the error to the actual costs reported on the SEFA results in a likely questioned cost amount of $910. Cause: The individual in charge of entering the purchase into Microix did not code the alcoholic beverages to a separate general ledger account that was established to track unallowable costs so that they are not charged to the federal programs. Effect: Without adequate controls in place to ensure costs are allowable, Sound Generations runs the risk of being out of compliance with not only the major program but all federal programs. Repeat Finding: No. Recommendation: CLA recommends that emphasis be placed (via an employee training or organization-wide email) on specifically disallowed costs and the importance of tracking these costs separately so that they are not charged to federal programs. Views of responsible officials: Please see the attached Management’s Corrective Action Plan.
Finding 2022-001: (21.027) Unallowable Activities/Allowable Costs and Cost Principals Criteria: As specified in Section 2 CFR 200.423, General Provisions for Selected Items of Cost-Alcoholic Beverages, costs of alcoholic beverages are unallowable. Condition: An amount of $329.25 for the purchase of alcoholic beverages was reimbursed to the School with federal funds.. Cause: Certain expenditures were not correctly identified and excluded from reimbursement requests. Effect: The School was not in compliance with award and federal statutes. The School is potentially subject to federal funding cuts or other punitive actions. Recommendation: The School should ensure that expenditures are compiled and reviewed to meet the terms and conditions of the award and federal statutes. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying Management?s Corrective Action Plan.
Type of Finding: • Significant Deficiency in Internal Control over Compliance – Allowable Costs/Cost Principles • Other Matter – Non-Compliance with Allowable Costs/Cost Principles Compliance Requirements Federal Agency: Department of Transportation Federal Program Name: Enhanced Mobility of Seniors and Individuals with Disabilities Assistance Listing Number: 20.513 Federal Award Identification Number and Year: PTD0287-2022 Pass-Through Agency: WADOT Pass-Through Number(s): PTD0287 Award Period: July 1, 2021 through June 30, 2023 Criteria or specific requirement: 2 CFR 200.423 specifically identifies alcoholic beverages as unallowable costs. Condition: CLA noted one sample in which federal funds were expended on unallowable costs. Questioned costs: $85 known, $910 likely Context: A sample of 25 was made from a population of 942 nonpayroll-related general disbursement costs charged to the major program. Of the 25 sampled costs, one was found to be out of compliance with the requirements of Allowable Costs / Cost Principles, totaling $85. Sampled nonpayroll-related general disbursement costs totaled $24,560. General disbursements totaled $263,090 of the $1,706,762 tracked to the major program. Extrapolating the error to the actual costs reported on the SEFA results in a likely questioned cost amount of $910. Cause: The individual in charge of entering the purchase into Microix did not code the alcoholic beverages to a separate general ledger account that was established to track unallowable costs so that they are not charged to the federal programs. Effect: Without adequate controls in place to ensure costs are allowable, Sound Generations runs the risk of being out of compliance with not only the major program but all federal programs. Repeat Finding: No. Recommendation: CLA recommends that emphasis be placed (via an employee training or organization-wide email) on specifically disallowed costs and the importance of tracking these costs separately so that they are not charged to federal programs. Views of responsible officials: Please see the attached Management’s Corrective Action Plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Number: 14.850 Noncompliance ? B. Allowable Costs/Cost Principles Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Allowable Costs/Cost Principles Criteria: The Authority's federal program expenditures must meet the requirements of 2 CFR Part 200 Subpart E Cost Principles and must be adequately documented. Condition: Based upon inspection of the Authority?s paid invoices and on discussion with management, there were costs that were determined to be unallowable. Context: The following costs were determined to be unallowable or not reasonable or necessary in the proper and efficient performance of the federal program: ? Alcoholic beverages (2 CFR section 200.423) ? Training and education costs for a non-employee (2 CFR section 200.473) ? Meals (2 CFR section 200.438) Known Questioned Costs: $3,118 Cause: There is a significant deficiency in internal controls over the compliance for the allowable costs/cost principle type of compliance. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance with the allowable costs/cost principle requirements. Effect: The Public and Indian Housing Program is in non-compliance with the allowable costs/cost principle type of compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Number: 14.850 Noncompliance ? B. Allowable Costs/Cost Principles Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Allowable Costs/Cost Principles Criteria: The Authority's federal program expenditures must meet the requirements of 2 CFR Part 200 Subpart E Cost Principles and must be adequately documented. Condition: Based upon inspection of the Authority?s paid invoices and on discussion with management, there were costs that were determined to be unallowable. Context: The following costs were determined to be unallowable or not reasonable or necessary in the proper and efficient performance of the federal program: ? Alcoholic beverages (2 CFR section 200.423) ? Training and education costs for a non-employee (2 CFR section 200.473) ? Meals (2 CFR section 200.438) Known Questioned Costs: $3,118 Cause: There is a significant deficiency in internal controls over the compliance for the allowable costs/cost principle type of compliance. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance with the allowable costs/cost principle requirements. Effect: The Public and Indian Housing Program is in non-compliance with the allowable costs/cost principle type of compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis.