Finding 1154949 (2024-003)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2025-09-24

AI Summary

  • Core Issue: The Authority failed to pay a vendor within 3 business days after receiving federal funds, violating cash management requirements.
  • Impacted Requirements: Compliance with 2 CFR 200.305 (b) and HUD Capital Fund Guidebook Section 7.9 regarding timely disbursement of funds.
  • Recommended Follow-Up: Implement the reimbursement method to ensure payments are made to vendors before requesting funds from ELOCCs.

Finding Text

2024 -003 – CASH MANAGEMENT Significant Deficiency / Other Matter U.S. Department of Housing and Urban Development ALN #: 14.872 – Public Housing Capital Fund CRITERIA For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. (2 CFR 200.305 (b)) Once funds are disbursed, i.e. transferred from LOCCS to the PHA’s bank account, the PHA must pay the applicable bill(s) within 3 business days after the deposit of the funds into the PHA’s bank account. (HUD Capital Fund Guidebook; Section 7.9) CONDITION We selected a sample of 4 drawdowns of capital funds from ELOCCs during the year. We identified 1 instance in which the Authority did not process payment to the vendor within 3 business days of receiving the funds. CAUSE The Authority does not have sufficient procedures in place to coordinate the timing of drawdowns with disbursement schedules. EFFECT Federal funds were held in excess of immediate cash requirements, which is not in compliance with Uniform Guidance cash management requirements. QUESTIONED COSTS None Identified. CONTEXT The Authority had 8 drawdowns of capital funds during the year. We selected a sample of 4 drawdowns during the year. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority utilize the reimbursement method and process payment to the vendor before requisitioning funds from ELOCCs. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

Corrective Action Plan

Finding 2024-003: Cash Management Description of Finding: For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. (2 CFR 200.305 (b)) Once funds are disbursed, i.e. transferred from LOCCS to the PHA’s bank account, the PHA must pay the applicable bill(s) within 3 business days after the deposit of the funds into the PHA’s bank account. (HUD Capital Fund Guidebook; Section 7.9) Statement of Concurrence or NonConcurrence: A sample of 4 drawdowns of capital funds from ELOCCs during the year identified 1 instance in which the Authority did not process payment to the vendor within 3 business days of receiving the funds. Corrective Action: The Authority processes a weekly check run for all payables. The timing of the receipts from ELOCCs missed the run and the invoice was added to the following weekly run. The authority will better monitor the receipt of funds and if necessary perform an additional check run to disburse the funds to the recipient. Name of Contact Person: Cheryl Thibeault Projected Completion Date: 09/30/2025

Categories

Cash Management HUD Housing Programs Subrecipient Monitoring

Other Findings in this Audit

  • 1154947 2024-001
    Material Weakness Repeat
  • 1154948 2024-002
    Material Weakness Repeat
  • 1154950 2024-004
    Material Weakness Repeat
  • 1154951 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $9.99M
14.850 Public Housing Operating Fund $4.34M
14.872 Public Housing Capital Fund $1.12M
14.896 Family Self-Sufficiency Program $185,455
14.870 Resident Opportunity and Supportive Services - Service Coordinators $81,199