Finding 1153871 (2024-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-09-22
Audit: 366932
Organization: Chicago Housing Authority (IL)
Auditor: Ernst Young LLP

AI Summary

  • Core Issue: The Authority failed to keep necessary documentation for the utility allowance schedule, which is crucial for compliance with federal regulations.
  • Impacted Requirements: This affects the internal control requirements under 2 CFR section 200.303 and the annual review of utility rates as mandated by 24 CFR section 982.517.
  • Recommended Follow-Up: The Authority should establish and maintain proper documentation and controls for the utility allowance schedule to ensure accuracy and compliance.

Finding Text

Finding 2024-003 N. Special Tests and Provisions: N3. Utility Allowance Schedule Identification of the federal program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) Federal Assistance Listing Number: 14.881 Federal Program Name: Moving to Work (MTW) Demonstration Program Rental Assistance Demonstration (RAD) Program Year: January 1, 2024 through December 31, 2024 Program No.: Multiple Criteria or specific requirement (including statutory, regulatory or other citation): The Uniform Guidance 2 CFR section 200.303 states, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” “The PHA must maintain an up-to-date utility allowance schedule. The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised (24 CFR section 982.517).” Condition: RAD – The underlying details supporting the analysis of changes in utility rate data and evidence of review over the annual utility allowance schedule were not retained. Cause: RAD – Supporting documentation for the inputs to the utility allowance schedule analysis of changes in utility rate data prepared by a third-party service provider and evidence of review over the annual utility allowance schedule by Authority management were not retained by the Authority. Effect or Potential Effect: RAD – The utility allowance schedule could be inaccurate or incomplete. Questioned Costs: None. Context: The RAD program had 5,706 tenants on its rent rolls as of December 31, 2024. Identification as a Repeat Finding, if Applicable: This finding is a partial repeat of finding 2024-004 from the prior year. Recommendation: RAD – The Authority should implement and retain supporting documentation of internal controls over the utility allowance schedule and amounts reported on line 12m or 15g of the Form HUD-50058. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.

Corrective Action Plan

Finding 2024-003 N. Special Tests and Provisions: N3. Utility Allowance Schedule – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: The Authority acknowledges the finding regarding the retention of supporting documentation for the utility allowance schedule analysis and related approvals. To address this, the CHA has established a Compliance Team to oversee documentation retention and review processes. In 2025, CHA has instituted procedures to ensure all supporting documentation is retained, including: • Inputs from the third-party vendor’s analysis of utility allowance schedule changes; • Evidence of management’s review and approval of the annual utility allowance schedule; • Signed and dated utility allowance notice with effective date instructions and copies of the new schedules. • The final report is maintained in a central location by the user group, ensuring accessibility for reference and audit purposes. Timeline • Implementation began Quarter 3 2025 and is ongoing. Contact Person: Leonard Langston, Jr., Interim Chief Property Officer Anticipated Completion Date: End of 3rd Qtr. 2026

Categories

HUD Housing Programs Special Tests & Provisions Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1153869 2024-001
    Material Weakness Repeat
  • 1153870 2024-002
    Material Weakness Repeat
  • 1153872 2024-004
    Material Weakness Repeat
  • 1153873 2024-005
    Material Weakness Repeat
  • 1153874 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $1.06B
14.871 Section 8 Housing Choice Vouchers $17.37M
14.856 Lower Income Housing Assistance Program Section 8 Moderate Rehabilitation $4.36M
14.879 Mainstream Vouchers $4.25M
10.565 Commodity Supplemental Food Program $1.54M
14.895 Jobs-Plus Pilot Initiative $1.35M
14.896 Family Self-Sufficiency Program $1.34M
14.870 Resident Opportunity and Supportive Services - Service Coordinators $310,690