Finding Text
Finding 2024-005 N. Special Tests and Provisions: N1. Wage Rate Requirements 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 Public and Indian Housing (Public Housing) Program Year: January 1, 2024 through December 31, 2024 Program No.: IL002-01-00024D 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).” Condition: For three of 24 (12.5%) contracts/task orders sampled to test the Authority’s internal control to ensure certified payroll reports (CPRs) are submitted by contractors/subcontractors, we noted the following: • For one (4.2%) of the 24, the contract summary checklist completed at contract closeout was not prepared or reviewed correctly, as it was noted that CPR findings were still outstanding and the contract could not be closed. • For two (8.3%) of the 24, the reviewed contract summary checklist was not provided. Cause: The Authority’s internal control to ensure all CPRs have been submitted prior to contract closeout was not operating effectively. Effect or Potential Effect: Required CPRs from contractors and subcontractors may not be submitted. Questioned Costs: None. Context: Public Housing expenditures reported in the schedule of expenditures of federal awards were $171,219,053 for the year ended December 31, 2024, representing 15.1% of total federal expenditures under Assistance Listing No. 14.881 of $1,106,629,432. Identification as a Repeat Finding, if Applicable: This finding is not a repeat finding from the prior year. Recommendation: The Authority should follow its established internal control to ensure all CPRs are submitted by contractors/subcontractors prior to contract closeout. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.