Finding Text
Missing Required Moving to Work (MTW) Demonstration Program Documentation (ALN 14.881)
Condition: During our review of the Authority's administration of the MTW Program, the Authority was unable to provide a copy of its Annual Contributions Contract (ACC), which serves as the foundational agreement between the Authority and HUD for the receipt and use of federal funds.
Criteria: Under 2 CFR §200.302 and §200.334, non-Federal entities must maintain effective control over and access to records that support compliance with federal program requirements. The MTW Operations Notice (85 FR 10232) and the Authority's MTW ACC Amendment require that the PHA maintain and certify compliance with its MTW Plan and statutory objectives. The ACC establishes the legal basis for receiving and administering MTW-related federal funds.
Cause: The Authority did not have adequate internal procedures to ensure that foundational program documents were retained, tracked, and made available for audit and oversight purposes.
Effect: The absence of the Annual Contributions Contract (ACC) impairs verification of the Authority's legal authority to receive and administer HUD funds under the MTW program and may result in HUD compliance findings, delayed approvals, or other administrative sanctions.
Questioned Costs: None
Recommendation: The Authority should obtain and retain a copy of its executed ACC for audit and HUD monitoring purposes and establish or strengthen internal controls to track and retain all required MTW program records and certifications in accordance with HUD guidance and federal record retention requirements.
Reply and Corrective Action Plan: To address missing foundational documentation, the Authority will locate and archive its Annual Contributions Contract (ACC), the required supplement to the annual MTW Plan, the HUD-issued approval letter for the supplement, and complete the MTW Certification of Compliance for the most recent fiscal year.