Finding Text
2023-003 Special Tests and Provisions – Inter-Program Fund Management Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Voucher Cluster (Section 8): Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control, Material Noncompliance Condition: There were inter-program borrowings using federal funds which are unauthorized distributions, resulting in $3,943,604 of the total $4,164,790 in inter-program "due from" and "due to" balances lacking supporting documentation or reconciliation schedules. The unsupported balances primarily consist of significant amounts due to the Public Housing program, including $1,590,789 due to AMP 2 and $2,200,000 due to AMP 199 HOPE VI. These are offset by significant amounts owed by the Housing Choice Voucher program ($1,458,947) and the Central Office Cost Center ($2,190,705). Criteria: HUD regulations and the requirements of 2 CFR 200 specify that federal funds should be accounted for by program and used for their intended purposes. To ensure compliance, sound internal controls require that all balance sheet accounts, including inter-program "due from" and "due to" balances, are supported by detailed documentation that clarifies their purpose and confirms they are valid and recoverable. Questioned Costs: The entire unsupported inter-program balance of $3,943,604 is identified as a questioned cost. This is because the lack of documentation and the apparent use of funds from one federal program to cover the expenses of another is a violation of federal cash management requirements. Effect: This condition is considered a material weakness in internal control. It raises concerns regarding compliance with federal cash management regulations, as it becomes difficult to demonstrate that funds were managed appropriately without documentation. Furthermore, the unsupported balances compromise the reliability of the individual program-level financial records, making it difficult to confirm the collectability of amounts 'due from' one program and the completeness of amounts 'due to' another." Cause: A standardized process for documenting, authorizing, and settling inter-program cash activity has not yet been fully implemented. As a result, transfers have occurred to meet short-term cash needs, leading to the accumulation of large, unsupported balances over time. Auditor’s Recommendation: To strengthen internal controls and ensure compliance, it is recommended that the Authority perform a detailed analysis to identify and document the specific transactions comprising the outstanding inter-program balances. Based on this analysis, a formal plan should be developed to resolve and settle these balances. To prevent a recurrence, the Authority should also establish and implement written policies that outline clear requirements for proper authorization, documentation, and timely settlement of any future inter-program transactions. Specifically, the inter-program amounts should be settled every month and balances should not be carried forward. Finally, ongoing compliance can be ensured by incorporating a monthly reconciliation of all "due from" and "due to" accounts into the regular financial closing process. Views of Responsible Officials of the Auditee: The Authority agrees with the finding and has taken corrective action. See the “Action Taken” on the Corrective Action Plan.