Finding 1167847 (2021-003)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2021
Accepted
2026-01-05
Audit: 379196
Auditor: BCM LLC

AI Summary

  • Core Issue: NMHC submitted inaccurate financial information to HUD, mixing up funding sources and misreporting revenues.
  • Impacted Requirements: Noncompliance with the Uniform Financial Reporting Standards, specifically regarding timely and accurate GAAP-based submissions.
  • Recommended Follow-Up: NMHC should enhance monitoring controls and ensure timely reconciliation of general ledger accounts to prevent future discrepancies.

Finding Text

Finding No.: 2021-003 Federal Agency: U.S. Department of Housing and Urban Development CFDA Program: 14.871 Section 8 Housing Choice Vouchers Area: Eligibility Questioned Costs: $-0- Criteria: The Uniform Financial Reporting Standards require PHAs to submit timely GAAP-based unaudited financial information electronically to HUD that is accurately prepared. Condition: Tests of the unaudited single audit information for the year ended September 30, 2021 that was electronically submitted to HUD noted the following: Program Balance Sheet Summary: Program Revenue and Expense Summary: For the amount reported in line item 124, the account pertains to 14.EHV Emergency Housing Voucher (EHV) program in the General Ledger, not the 14.871 Housing Choice Voucher (HCV) program per the REAC submission. For the $422,949 reported under 14.EHV Emergency Housing Vouchers Funding column for FDS line 70600, amount pertains to EHV funding that NMHC received in FY 2021, however, NMHC only incurred $23,392 in EHV expenses. The variance should not be reported as grant revenue but rather as unearned revenue at FDS line 342 per the revenue recognition guideline on HUD’s Notice PIH-2020-24. For the variance reported in line 166, this pertains to the FY 2021 adjustment to reconcile accumulated depreciation as of 09/30/2021. Cause: The cause of the above condition is the lack of monitoring controls over the Uniform Financial Reporting Standards reporting and untimely reconciliation of its general ledger accounts. In addition, NMHC not including accrued revenues at FDS Line 70600 is due to comments that NMHC received from REAC reviewer that the FDS and VMS should totally agree or closely match. Accordingly, as the VMS reporting is on a cash basis, amount reported at FDS Line 70600 was based on a modified cash basis to agree amounts to the VMS reporting and facilitate approval from the REAC reviewer. Effect: NMHC is in noncompliance with the Uniform Financial Reporting Standards reporting requirements. Identification of Repeat Finding: Finding No. 2020-009 Recommendation: NMHC should strengthen controls over compliance with applicable Uniform Financial Reporting Standards reporting requirements and the timely reconciliation of its general ledger accounts. Views of Responsible Officials: NMHC agrees with this finding. Corrective Action: NMHC will strengthen controls over compliance with applicable Uniform Financial Reporting Standards reporting requirements and the timely reconciliation of its general ledger accounts. NMHC will make sure to distinguish the reporting between the VMS and FDS for reporting purposes only. Finding No.: 2021-003 Federal Agency: U.S. Department of Housing and Urban Development CFDA Program: 14.871 Section 8 Housing Choice Vouchers Area: Eligibility Questioned Costs: $-0- Criteria: The Uniform Financial Reporting Standards require PHAs to submit timely GAAP-based unaudited financial information electronically to HUD that is accurately prepared. Condition: Tests of the unaudited single audit information for the year ended September 30, 2021 that was electronically submitted to HUD noted the following: Program Balance Sheet Summary: Program Revenue and Expense Summary: For the amount reported in line item 124, the account pertains to 14.EHV Emergency Housing Voucher (EHV) program in the General Ledger, not the 14.871 Housing Choice Voucher (HCV) program per the REAC submission. For the $422,949 reported under 14.EHV Emergency Housing Vouchers Funding column for FDS line 70600, amount pertains to EHV funding that NMHC received in FY 2021, however, NMHC only incurred $23,392 in EHV expenses. The variance should not be reported as grant revenue but rather as unearned revenue at FDS line 342 per the revenue recognition guideline on HUD’s Notice PIH-2020-24. For the variance reported in line 166, this pertains to the FY 2021 adjustment to reconcile accumulated depreciation as of 09/30/2021. Cause: The cause of the above condition is the lack of monitoring controls over the Uniform Financial Reporting Standards reporting and untimely reconciliation of its general ledger accounts. In addition, NMHC not including accrued revenues at FDS Line 70600 is due to comments that NMHC received from REAC reviewer that the FDS and VMS should totally agree or closely match. Accordingly, as the VMS reporting is on a cash basis, amount reported at FDS Line 70600 was based on a modified cash basis to agree amounts to the VMS reporting and facilitate approval from the REAC reviewer. Effect: NMHC is in noncompliance with the Uniform Financial Reporting Standards reporting requirements. Identification of Repeat Finding: Finding No. 2020-009 Recommendation: NMHC should strengthen controls over compliance with applicable Uniform Financial Reporting Standards reporting requirements and the timely reconciliation of its general ledger accounts. Views of Responsible Officials: NMHC agrees with this finding. Corrective Action: NMHC will strengthen controls over compliance with applicable Uniform Financial Reporting Standards reporting requirements and the timely reconciliation of its general ledger accounts. NMHC will make sure to distinguish the reporting between the VMS and FDS for reporting purposes only. Finding No.: 2021-003 Federal Agency: U.S. Department of Housing and Urban Development CFDA Program: 14.871 Section 8 Housing Choice Vouchers Area: Eligibility Questioned Costs: $-0- Criteria: The Uniform Financial Reporting Standards require PHAs to submit timely GAAP-based unaudited financial information electronically to HUD that is accurately prepared. Condition: Tests of the unaudited single audit information for the year ended September 30, 2021 that was electronically submitted to HUD noted the following: Program Balance Sheet Summary: Program Revenue and Expense Summary: For the amount reported in line item 124, the account pertains to 14.EHV Emergency Housing Voucher (EHV) program in the General Ledger, not the 14.871 Housing Choice Voucher (HCV) program per the REAC submission. For the $422,949 reported under 14.EHV Emergency Housing Vouchers Funding column for FDS line 70600, amount pertains to EHV funding that NMHC received in FY 2021, however, NMHC only incurred $23,392 in EHV expenses. The variance should not be reported as grant revenue but rather as unearned revenue at FDS line 342 per the revenue recognition guideline on HUD’s Notice PIH-2020-24. For the variance reported in line 166, this pertains to the FY 2021 adjustment to reconcile accumulated depreciation as of 09/30/2021. Cause: The cause of the above condition is the lack of monitoring controls over the Uniform Financial Reporting Standards reporting and untimely reconciliation of its general ledger accounts. In addition, NMHC not including accrued revenues at FDS Line 70600 is due to comments that NMHC received from REAC reviewer that the FDS and VMS should totally agree or closely match. Accordingly, as the VMS reporting is on a cash basis, amount reported at FDS Line 70600 was based on a modified cash basis to agree amounts to the VMS reporting and facilitate approval from the REAC reviewer. Effect: NMHC is in noncompliance with the Uniform Financial Reporting Standards reporting requirements. Identification of Repeat Finding: Finding No. 2020-009 Recommendation: NMHC should strengthen controls over compliance with applicable Uniform Financial Reporting Standards reporting requirements and the timely reconciliation of its general ledger accounts. Views of Responsible Officials: NMHC agrees with this finding. Corrective Action: NMHC will strengthen controls over compliance with applicable Uniform Financial Reporting Standards reporting requirements and the timely reconciliation of its general ledger accounts. NMHC will make sure to distinguish the reporting between the VMS and FDS for reporting purposes only.

Corrective Action Plan

Corrective Action: NMHC will strengthen controls over compliance with applicable Uniform Financial Reporting Standards reporting requirements and the timely reconciliation of its general ledger accounts. NMHC will make sure to distinguish the reporting between the VMS and FDS for reporting purposes only.

Categories

HUD Housing Programs Reporting

Other Findings in this Audit

  • 1167846 2021-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $6.99M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $3.70M
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $2.03M
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $1.44M
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $1.05M
14.225 COMMUNITY DEVELOPMENT BLOCK GRANTS/SPECIAL PURPOSE GRANTS/INSULAR AREAS $582,007
14.871 HOUSING CHOICE VOUCHER CARES ACT PROGRAM HCC $24,218
14.871 EMERGENCY HOUSING VOUCHER PROGRAM EHV $23,392