Finding 1156466 (2024-001)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-09-29

AI Summary

  • Core Issue: Unauthorized payments of $13,250 were made from Project cash to an affiliate without prior HUD approval.
  • Impacted Requirements: Loans from Project funds must be authorized by HUD; failure to comply results in questioned costs.
  • Recommended Follow-Up: Management should improve procedures to ensure all joint invoice payments are either approved by HUD or paid by the Sponsor, not the Corporation.

Finding Text

Finding No. 2024-001 - Allowable Costs / Cost Principals - Significant Deficiency Name of Federal Agency: Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Assistance Listing Number: 14.157 Federal Award Identification Number and Year: N/A Name of Pass-through Entity (if applicable): N/A Criteria Loans are not permitted to be made from Project cash without prior authorization from HUD. Condition During the year ended December 31, 2024, the Project paid expenses in the amount of $13,250 on behalf of an affiliate from Project cash without HUD approval. The amount due to the Project as of December 31, 2024 is $13,250. Cause Procedures were not in place to ensure that cash disbursements of Project funds were limited to Project operating costs. Effect or Potential Effect The payments of $13,250 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $13,250 Context The project is billed for a shared invoice, and was not reimbursed from the affiliates timely. Identification as a Repeat Finding No. Recommendation Management has already reimbursed the Corporation. Management should revisit the procedures in place to ensure payments of this nature, being joint invoices, are either approved by HUD or not made in the future from the Corporation, but from the Sponsor. HUD Auditor Noncompliance Code: G - Unauthorized loans from project assets Uniform Guidance Auditor Noncompliance Code: B - Allowable Costs/Cost Principles Finding Resolution Status: Resolved Views of Responsible Officials Council Towers Housing Development Fund Corporation agrees with the finding and the auditor’s recommendations. Workers comp policy was opened under Council Towers Housing Development Fund Corporation to cover union workers in Council Towers Housing Development Fund and 3 other affiliates. Council Towers Housing Development Fund Corporation would pay for the policy and be reimbursed by the affiliates. In 2024 the amount owed was much higher due to an miscalculation by management, where they included other employees that were not covered by policy in their payroll audit. After TUC negotiated with NYSIF the bill was corrected. It was paid at the end of 2024. Council Towers Housing Development Fund Corporation was reimbursed by the affiliates in 2025.

Corrective Action Plan

We are planning to close the current policy. We are opening a separate policy for Council Towers II, Council Towers III and Council Towers IV that we covered by that policy.

Categories

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking

Programs in Audit

ALN Program Name Expenditures
14.157 Supportive Housing for the Elderly $1.96M