Finding Text
2 CFR § 2400.101 - Internal Control Failures for Eligibility
Finding Number: 2024-001
Assistance Listing Number and Title: AL # 14.850 Public Housing Operating
Federal Award Identification Number / Year: OH028-00000123D/2023 and OH028-
00000124D/2024
Federal Agency: U.S. Department of Housing and Urban
Development
Compliance Requirement: Determine that the required eligibility
determinations and redeterminations were performed, and individual was determined to be eligible in accordance with the compliance requirements of the program.
Pass-Through Entity: None
Repeat Finding from Prior Audit? No
Material Weakness
2 CFR § 2400.101 gives regulatory effect to the Department of Housing & Urban Development for 2 CFR § 200.303 which requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain effective internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
24 CFR § 960.253 provides that once a year, the Authority must give each family the opportunity to choose between the two methods for determining the amount of tenant rent payable monthly by the family.
24 CFR § 960.257 provides that the Authority must reexamine family income and composition at least once every 12 months and adjust the tenant rent as necessary using the documentation from third party verification
Due to deficiencies in the Authority's internal controls over compliance requirements, ten percent of applications tested for eligibility compliance did not have sufficient documentation to demonstrate that examination was reviewed before certification and that the tenant was given a choice between the two methods prior to the examination's completion.
Failing to properly determine eligibility could result in the Authority improperly admitting ineligible tenants and making improper payments. The Authority should review the applications for accuracy and ensure that proper documentation is maintained of those which meet the eligibility guidelines set for the Public Operating Fund.