Finding 1187058 (2025-001)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2025
Accepted
2026-03-26

AI Summary

  • Core Issue: The Authority misclassified Capital Fund drawdowns for operating costs, violating HUD guidelines.
  • Impacted Requirements: Capital Funds can only be used for operating costs if included in the approved 5-Year Action Plan and limited to 20% for PHAs with 250+ units.
  • Recommended Follow-Up: Strengthen internal controls to ensure compliance with HUD’s Capital Fund Guidebook and review eligibility of costs regularly.

Finding Text

2025-001 – ACTIVITIES ALLOWED OR UNALLOWED Material Noncompliance / Material Weakness U.S. Department of Housing and Urban Development ALN #: 14.872 – Public Housing Capital Fund CRITERIA A PHA may use Capital Funds for operating costs only if it is included in the CFP 5-Year Action Plan that is approved by the PHA Board of Commissioners and HUD… A PHA with 250 or more units may use no more than 20 percent of its annual Capital Fund grant for activities that are eligible under the Operating Fund at 24 CFR part 990. (24 CFR 905.314 (I)) CONDITION Prior to year-end audit adjustments, the Authority recorded unearned revenue related to the 2023 and 2024 Capital Fund Formula Grants drawdowns for operations on the Central Office Cost Center. This amount should have been reflected as revenue on the public housing programs. CAUSE The Authority’s internal controls did not prevent the misunderstanding of the guidance contained in HUD’s Capital Fund Guidebook related to the use of Capital Funds for operations and the Authority incorrectly recorded the draw down for capital funds for operating costs. EFFECT As a result, prior to adjustments, the financial position of the public housing programs appeared to be worse off than it actually was which could lead management to make decisions that are not in the best interest of the Public Housing program. QUESTIONED COSTS None identified as the Public Housing Program was reimbursed. CONTEXT We selected a sample of 15 transactions charged to the Capital Fund Program from a population of approximately 150 transactions. This represented approximately 81% of Capital Fund Program Costs. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority enhance internal controls to ensure a review by those involved with the project the guidance contained in HUD’s Capital Fund Guidebook and the requirements of 24 CFR 905.202 related to eligible costs of the Capital Fund Program. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

Corrective Action Plan

2025-001 Federal Ward Findings and Questioned Costs Material Noncompliance/Material Weakness ALN: 14.872 Public Housing Capital Fund Finding summary: The Authority recorded unearned revenue related to the Capital Fund drawdowns for operations on the Central Office Cost Center. This amount should have been reflected as revenue on the public housing programs. Statement of Concurrence: The Authority agrees with the finding. Corrective Action Plan: The Authority did not spend capital fund draw downs on the COCC program. The Authority’s practice was to record drawdowns as deferred revenue on COCC until they were spent and at that time moved the expenditures to the public housing programs. Going forward the Authority will record the drawdowns as revenue for the public housing programs when they are drawn down. Effective immediately, the Comptroller, Jennifer Yager, will implement this policy. Jennifer can be reached at 203-596-2640 and Jennifer.yager@waterburyha.org.

Categories

HUD Housing Programs Cash Management

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $27.98M
14.850 PUBLIC AND INDIAN HOUSING $5.26M
14.872 PUBLIC HOUSING CAPITAL FUND $3.97M
14.856 LOWER INCOME HOUSING ASSISTANCE PROGRAM SECTION 8 MODERATE REHABILITATION $1.59M
14.879 MAINSTREAM VOUCHERS $1.54M
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $420,000
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $130,406
14.888 LEAD-BASED PAINT CAPITAL FUND PROGRAM $77,907
14.249 SECTION 8 MODERATE REHABILITATION SINGLE ROOM OCCUPANCY $64,340