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2024-001 – INTERNAL CONTROLS OVER COMPLIANCE Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development ALN #: 14.871 – Housing Choice Voucher Program ALN #: 14.850 – Public Housing Operating Fund CRITERIA A recipient of federal funding must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. (2 CFR 200.303(a)) CONDITION During our review of internal controls over compliance, which included reviewing monitoring reports from federal agencies, we identified the following matters: • The Authority did not have a policy in place governing the use of HUD’s Enterprise Income Verification (EIV) system. • The Authority was not following its administrative plan for the Housing Choice Voucher program related to minimum rents. The Authority has not established a minimum rent policy for Public Housing. • The Authority did not have a written methodology for how it conducts annual quality control reviews of HCV participant files. • The Authority did not follow its administrative plan regarding terminating participant from the Housing Choice Voucher Program. The Authority did not have a policy addressing participants being terminated from the Public Housing Program. • The VHA was not in compliance with updated Violence Against Women Act (VAWA) requirements. • The Authority’s day-to-day practices for the administration of the Public Housing program differ from the Admissions and Continued Occupancy Policy. • The Authority did not have a Section 3 policy. • The Authority did not follow its Administrative Plan related to preferences for the Project Based Voucher (PBV) waiting list. CAUSE The Authority did not perform a review and update its compliance policies for changes in HUD regulations. EFFECT The lack of updated or written policies increases the risk of noncompliance with federal requirements, as staff may not have clear guidance. QUESTIONED COSTS None identified. CONTEXT The Authority administers both the Housing Choice Voucher and Public Housing Programs. Uniform Guidance requires the Authority to have written policies related to compliance with federal statutes, regulations, and terms of federal awards. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Authority review all compliance-related policies and procedures and update or develop written documentation to align with current Uniform Guidance requirements. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.