Finding 1181682 (2025-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-20

AI Summary

  • Core Issue: The Public Housing Authority (PHA) is missing key tenant eligibility documents, leading to non-compliance with HUD requirements.
  • Impacted Requirements: Essential documentation, such as original applications and citizenship declarations, were unavailable during the audit, violating 24 CFR regulations.
  • Recommended Follow-Up: Strengthen internal controls by establishing formal procedures for collecting and maintaining tenant eligibility documents, and conduct regular internal reviews to ensure compliance.

Finding Text

Finding 2025-003 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 – E. Eligibility Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 960.259). Determine income eligibility and calculate the tenant's rent payment using the documentation from third party verification in accordance with 24 CFR Part 5, Subpart F (24 CFR sections 5.601 et seq.) and 24 CFR Subpart C sections 960.253, 960.255, and 960.259). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately six hundred forty seven (647) Public and Indian Housing units. Of a sample size of twenty (20) tenant files, the following information was unavailable for examination at the time of audit:  Original applications were missing in six (6) files  Declaration of citizenship forms were missing in six (6) files Our sample size is statistically valid. Known Questioned Costs: Unknown Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. 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 eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority strengthen internal controls over eligibility compliance by implementing formal procedures to ensure all required tenant eligibility documentation is obtained, reviewed, retained, and readily available for examination. Management should also perform periodic internal reviews of tenant files to confirm completeness and compliance with HUD requirements. These procedures will reasonably assure compliance with the Uniform Guidance and the compliance supplement.

Corrective Action Plan

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program including implementation of formal policies, reconciliation procedures, and enhanced oversight of interfund activity to ensure that established internal control policies are being followed on a timely basis. Steve Arlinghaus, Executive Director, is responsible for implementing this corrective action by June 30, 2026.

Categories

HUD Housing Programs Eligibility Significant Deficiency

Other Findings in this Audit

  • 1181681 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.850 PUBLIC AND INDIAN HOUSING $3.02M
14.872 PUBLIC HOUSING CAPITAL FUND $2.53M
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $76,732
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $54,387