Finding 1169878 (2025-003)

Material Weakness Repeat Finding
Requirement
EN
Questioned Costs
-
Year
2025
Accepted
2026-01-21
Audit: 383033
Organization: City of Concord (NC)

AI Summary

  • Core Issue: The City failed to ensure proper eligibility determinations and documentation for applicants, leading to potential ineligible benefits.
  • Impacted Requirements: Compliance with 2 CFR 200 and 24 CFR regulations regarding tenant eligibility and waiting list procedures was not met.
  • Recommended Follow-Up: Review tenant files to confirm accurate calculations and obtain all necessary documentation before approving benefits.

Finding Text

Non-Material Non-Compliance Material Weakness, Eligibility, Special Tests and Provisions Criteria: In accordance with 2 CFR 200, management should have an adequate system of internal control procedures in place to ensure that applicants have all required documentation in their file. In accordance with 24 CFR Part 5 Subpart F, the City must maintain documentation to support tenant eligibility. In accordance with 24 CFR sections 960.202 through 960.208, the City must establish, adopt, and follow policies for admission of tenants as it relates to the Public Housing waiting list. All families admitted to the program must be selected from the waiting list. Condition: The City did not follow procedures to ensure the proper eligibility determinations were made and documented. Context: Of the 163 applicants during the current year valued at $518,453, we examined 33 (valued at $100,361) and determined that 2 (7% valued at $16,692) applicants were not supported with case documentation to confirm eligibility. Of the 33 applicants we examined, we determined that 1 (3%) applicant did not have documentation to confirm they were selected from the waiting list. Upon further review, the applicant is deemed eligible. Effect: Participants could receive benefits for which they are not eligible Cause: Weakness in implementation of controls over eligibility procedures Identification of a Repeat Finding: This is modified and a repeat of Finding 2024-003 from the immediate previous audit. Questioned Cost: In accordance with 2 CFR 200, auditors are required to report known questioned costs when likely questioned costs are greater than $25,000. The sample results identified $16,692 in known questioned costs. Recommendation: Tenant files should be reviewed to verify that calculations are accurate, and all required documentation has been obtained before approving benefits. Views of Responsible Officials and Planned Corrective Actions: The City agrees with this finding. Please refer to the Corrective Action Plan section of this report.

Corrective Action Plan

Address weaknesses in eligibility verification and waiting list management: 1. Policy Review: Review and verify that the Admissions and Continued Occupancy Policy (ACOP) clearly states the requirement that all admissions originate from the approved waiting list and what documentation is required to be in the participate file as waitlist verification 2. Staff Training: Provide refresher training for Public Housing staff on eligibility verification and waiting list procedures. Require dual staff sign-off on all new admissions to confirm eligibility and waiting list documentation before lease execution. 3. Waiting List Audit: Conduct a semi-annual audit of waiting list transactions to ensure documentation accuracy and selection order compliance. 4. Software Updates: Review and select a new software to assist with income item collection. Software should allow residents to upload and store documentation. This will allow greater transparency as the residents and staff will view the same information. In addition, all information would be date and time stamped to ensure tasks were completed in a timely manner.

Categories

Special Tests & Provisions Eligibility HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1169876 2025-001
    Material Weakness Repeat
  • 1169877 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
20.507 FEDERAL TRANSIT FORMULA GRANTS $4.02M
14.850 PUBLIC HOUSING OPERATING FUND $1.10M
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $1.02M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $366,272
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $271,582
15.916 OUTDOOR RECREATION ACQUISITION, DEVELOPMENT AND PLANNING $257,914
20.526 BUSES AND BUS FACILITIES FORMULA, COMPETITIVE, AND LOW OR NO EMISSIONS PROGRAMS $239,588
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $181,782
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $177,773
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $150,822
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $121,337
20.505 METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON-METROPOLITAN PLANNING AND RESEARCH $94,782
97.137 STATE AND LOCAL CYBERSECURITY GRANT PROGRAM TRIBAL CYBERSECURITY GRANT PROGRAM $62,180
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $49,819
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $46,740
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $34,733
14.872 PUBLIC HOUSING CAPITAL FUND $27,875
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $22,066
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $14,524
16.922 EQUITABLE SHARING PROGRAM $10,000
20.205 HIGHWAY PLANNING AND CONSTRUCTION $8,900
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $3,306