FAC Explorer

Finding 1157537 (2024-004)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369754
Organization: Housing Authority of Baltimore City (MD)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The Authority failed to complete FFATA reporting for subcontractors in the Choice Neighborhood Implementation program.
  • Impacted Requirements: This finding indicates non-compliance with the Transparency Act, specifically the requirement to report first-tier subawards of $30,000 or more.
  • Recommended Follow-Up: HABC staff should enhance monitoring controls to ensure FFATA reporting is complete, accurate, and ready for audit.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOPE VI Cluster Assistance Listing Number: 14.889 Federal Award Identification Number and Year: MD3B002CNG122 Award Period: 1/1/2024-12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or specific requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110- 252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: FFATA reporting was not completed for the Choice Neighborhood Implementation program's subcontractors. Questioned costs: None Context: FFATA reporting was not completed for the subcontractors. Cause: The Authority did not sufficiently monitor controls to ensure compliance with FFATA reporting requirements. Effect: The Authority is not in compliance with federal regulations regarding FFATA reporting. Repeat Finding: Not a repeat finding. Recommendation: We recommend that HABC staff review the controls in place to ensure that required FFATA reporting documentation is complete, accurate, and available for audit. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Choice Neighborhood Incentive Grants – Assistance Listing No. 14.889 Recommendation: We recommend that HABC staff review the controls in place to ensure that required FFATA reporting documentation is complete, accurate, and available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Public Law 109-282, known as the Federal Funding Accountability and Transparency Act of 2006 (FFATA), mandates the public disclosure of all entities and organizations receiving federal funds through a single accessible website. Any subcontract exceeding $30,000 must be reported by the prime recipient of federal funds. However, this reporting requirement does not apply to the Housing Authority of Baltimore City (HABC), similar to the Moving to Work (MTW) block grants and their sub-recipient reporting to the Baltimore Regional Housing Partnership (BRHP). Both awards, the Choice Neighborhood Initiative (CNI) grant awards are not available in the dropdown menu for fulfilling this monthly reporting requirement. This issue was noted because HABC could not demonstrate to the auditors that we had made several unsuccessful attempts to meet this requirement. In response, HABC Finance has established a monthly workflow process to regularly check the website to document the attempts. In addition, we are currently awaiting a formal response from the Department of Housing and Urban Development (HUD) regarding the unavailability of these grants for sub-contracting monitoring & reporting on the SAMs website. Name(s) of the contact person(s) responsible for corrective action: Anu Francis, Chief Financial Officer. Planned completion date for corrective action plan: 12/31/2025

Categories

Subrecipient Monitoring Reporting Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1157536 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $443.49M
21.027 Coronavirus State and Local Fiscal Recovery Funds $10.29M
14.871 Section 8 Housing Choice Vouchers $4.70M
14.889 Choice Neighborhoods Implementation Grants $3.36M
14.879 Mainstream Vouchers $1.67M
14.870 Resident Opportunity and Supportive Services - Service Coordinators $522,142
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $498,981
14.856 Lower Income Housing Assistance Program Section 8 Moderate Rehabilitation $321,783
14.866 Demolition and Revitalization of Severely Distressed Public Housing $180,000
32.001 Affordable Connectivity Program $20,466