Finding Text
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Section 811 - Project Rental Assistance Program Assistance Listing Number: 14.326 Federal Award Identification Number and Year: IL06RDD1201 - 2012; IL06RDD1301 - 2013; IL06RDD1901 - 2019 Pass-Through Agency: State of Illinois Pass-Through Number: IL902 Award Period: July 1, 2024 to June 30, 2025 Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Finding 2025-001 Failure to Adequately Monitor Subrecipients CONDITION The Illinois Housing Development Authority (Authority) did not follow its established policies and procedures for monitoring subrecipients of the Section 811 Project Rental Assistance (Section 811) program. The Authority has implemented procedures whereby program staff perform property inspections over subrecipient compliance with regulations applicable to the Section 811 program. The Authority’s policies require the subrecipient to have an inspection every three years. During our testing of the monitoring of subrecipients, we noted one of eight (13%) subrecipients (with expenditures of $319,404 during the year ended June 30, 2025) had not received an inspection within the required three-year period in accordance with Authority policy. The most recent inspection for this subrecipient was conducted in fiscal year 2019. This sample was not intended to be, and was not, a statistically valid sample. CRITERIA OR SPECIFIC REQUIREMENT According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure that federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. In addition, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring inspections are performed in a timely manner. CAUSE Authority management indicated there are three underlying causes for this audit finding: 1) Increased volume in required inspections - the annual volume of required inspections in fiscal year 2025 was 56% higher than the annual required inspections in fiscal year 2020 while staffing remained constant. 2) COVID-19 Waivers - In 2020, the Internal Revenue Service issued COVID-19 waivers that eliminated physical inspection requirements and allowed a calendar “reset” for Low Income Housing Tax Credit transactions until 2023. The result of the increased volume and calendar “reset” created a significant backlog of physical inspections due. 3) Inadequate controls – lack of quality control procedures to ensure the inspection reports were completed and filed appropriately. EFFECT Failure to adequately perform inspections of subrecipients may result in subrecipients not properly administering the Federal programs in accordance with laws, regulations, and the grant agreement. (Finding Code No. 2025-001) RECOMMENDATION We recommend the Authority improve its internal controls to ensure inspections are completed in accordance with established policies and procedures. AUTHORITY RESPONSE The Authority agrees with the finding. The Authority will implement additional internal controls, including quality control of completed inspection, documentation, and inspection scheduling. Additionally, the Authority recognizes that the volume of required annual inspections has increased beyond existing Full Time Equivalent (FTE) capacity; therefore, an RFP for the third-party inspection vendor has been issued to supplement internal resources and support timely completion of inspections.