Finding Text
Finding 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Numbers: 14.850 Noncompliance – A. Activities Allowed or Unallowed Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Activities Allowed or Unallowed Criteria: Uniform Guidance (2 CFR §200.302(b)(3)) requires entities to maintain effective control over and accountability for all funds, property, and other assets and to adequately safeguard all assets used solely for authorized purposes. Additionally, HUD program regulations and the ACC require that Public and Indian Housing program funds be used only for eligible program costs and not commingled with other funds, except as permitted by HUD. Interfund and affiliate receivable/payable transactions recorded in a PHA’s books of account may indicate the existence of temporary loans which introduce the risk for the potential misuse of Operating funds for nonprogram purposes (42 USC 1437g(e)). Condition: Based upon inspection of the Authority’s files and on discussion with management, we noted that the Authority utilized interfund advances between the Public and Indian Housing program and other Authority funds to address short-term cash flow needs. These interfund balances were not consistently supported by formal agreements, repayment terms, or documented HUD approval where required. In addition, several interfund balances remained outstanding for extended periods and were not timely reconciled or settled. Context: Our testing identified multiple interfund balances between the Public and Indian Housing program and other Authority funds that were utilized for short-term cash flow purposes. Several of these balances remained outstanding for extended periods without formal documentation, repayment terms, or evidence of periodic reconciliation. Known Questioned Costs: Unknown Cause: There is a significant deficiency in internal controls over the compliance for the activities allowed or unallowed type of compliance related to misuse of interfunds. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Public and Indian Housing Program is in non-compliance with the activities allowed or unallowed type of compliance related to misuse of interfunds. The Authority was unable to demonstrate that Public and Indian Housing program funds were used exclusively for allowable program purposes. Prolonged outstanding interfund balances increase the risk of fund commingling, noncompliance with HUD requirements, and misstatement of program financial activity. Recommendation: We recommend that the Authority establish and implement formal policies governing interfund activity, including requirements for documentation, approval, repayment terms, and ongoing monitoring. Interfund balances should be reconciled regularly and settled timely. Management should also ensure that Public and Indian Housing program funds are used solely for allowable program purposes and that any interfund transactions comply with HUD and Uniform Guidance requirements.