Finding 1174269 (2025-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-02-19
Audit: 388015
Organization: Nevada Housing Authority (MO)

AI Summary

  • Core Issue: The Executive Director received questionable payments totaling $191,921 for personal and compensatory time without adequate documentation.
  • Impacted Requirements: Payments made from April 2025 lacked proper support, raising concerns about the authorization of salaries.
  • Recommended Follow-Up: The Board should closely monitor employee wages and address any potential misappropriation, while also reviewing and clarifying compensation and leave policies.

Finding Text

2025-001 Questioned Costs (Improper Payments) Criteria: Compensated or personal time paid to employees must be supported by adequate documentation. Condition: I noted that the Executive Director was paid from April 2025 to Dec 2025 for personal (unused vacation) or comp time (on call duty after normal work hours) dating back to 2019 as follows:  Personal time – 540 hours in the amount of $21,751.  Comp time – 4,080 hours in the amount of $170,170. Questioned Costs: $191,921. Effect: No assurance that the employee was receiving authorized salaries. Cause: The Authority did not maintain adequate documentation for the non-payroll hours paid from April 2025 to current. Recommendation: I recommend the Board pay strict attention to wages paid to all employees and take appropriate course of action if there is any impropriety or misappropriation of funds. Management’s Response: I acknowledge the audit comments related to the documentation and interpretation of compensatory and personal leave balances. Beginning in 2018, upon assuming expanded operational and acting leadership responsibilities, it was my understanding that overtime was no longer applicable due to the exempt status and that compensatory time was to be utilized under the personal policies in effect at that time. This understanding was applied consistently and in good faith as responsibilities evolved. This understanding was informed by the nature of the on-call responsibilities associated with my role, which required ongoing availability and personal schedule limitations outside of normal business hours. Between 2018 and 2022, I progressed through acting, assistant, deputy and executive leadership roles pursuant to documented personnel actions and Board involvement. These roles included on-call and after-hours responsibilities and impacted availability and leave usage. At the time of initial inquiry, I confirmed that documentation existed. Additional historical personnel records, payroll reconciliation detail, and policy context were subsequently compiled and are provided to further clarify the matter. My review of payroll records identified that leave balances were influenced by payroll system configuration, board-approval transitions to PTO, and subsequently board-approved leave adjustments. Upon identification of discrepancies, I took steps to correct records where appropriate. Relevant supporting documentation, including representative payroll records and personnel status forms reflecting assigned roles and pay grades, were maintained. While leaving usage was supported by existing balances and approvals, I recognize that evolving roles, policy structure, and documentation practices would benefit from additional clarification. I am in the process of reviewing compensation and leave practices with the Board of Commissioners to eliminate ambiguity and strengthen internal controls. Proposed actions to be presented to the Board to include elimination of compensatory time for executive-level staff, clarification of compensation and availability expectations, engagement with the Authority’s payroll provider to ensure accurate leave balance carryforward, and engagement of a third-party housing compliance firm to assist with a comprehensive review and update of personnel policies and procedures. The Authority has not had prior audit findings related to executive compensation or leave practices during my tenure. I remain committed to transparency, cooperation, and continued improvement of internal controls and administrative clarity.

Corrective Action Plan

Corrective action planned: During the audit review, questions were raised regarding compensatory and personal leave balances. Management notes that the amounts identified were processed through the Authority’s payroll system (ADP) and supported by existing leave balances, board-approval policy changes, and documented role assignments. The Executive Director held acting, assistant, deputy, and executive leadership roles during the periods referenced, as documented by personnel status forms and Board actions. These roles include on-call and after-hours responsibilities impacting availability and leave usage. Management’s review identified that leave balances were influenced by payroll system configuration, transitions to PTO approved by the Board, and subsequent board-approved leave adjustments. Upon identification of discrepancies, records were corrected where appropriate. Management will coordinate with the Authority’s payroll provider (ADP) to review system configuration and ensure leave balances carry forward accurately in accordance with approved policy, further strengthening internal controls and documentation consistency. In addition, management is undertaking a broader review of personnel policies and procedures. Management anticipates presenting proposed updates to the Board of Commissioners, including elimination of compensatory time for executive-level staff and clarification of compensation and availability expectations to improve administrative clarity going forward. Management believes these actions will strengthen internal controls, enhance transparency, and reduce the risk of future misinterpretation of leave and compensation practices. Contact person: Amanda Koehn, Executive Director. Anticipated completion date: Management anticipates completion of corrective actions by February 18, 2026, including implementation of payroll system review with ADP and Board approval of policy revisions eliminating comp time. Final written policy updates through Nelrod are anticipated to be completed no later than March 31, 2026, subject to vendor processing timelines.

Categories

Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
14.872 PUBLIC HOUSING CAPITAL FUND $687,635
14.850 PUBLIC HOUSING OPERATING FUND $528,033
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $298,112