Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 New Construction and Substantial Rehabilitation Federal Assistance Listing Numbers: 14.182 Noncompliance – E. Eligibility Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Federal Award Findings and Questioned Costs (continued) Finding 2025-001 (continued) 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 982.516). 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 four hundred fifteen (415) Section 8 New Construction units. Of a sample size of sixteen (16) tenant 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 Section 8 New Construction and Substantial Rehabilitation 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. Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will improve the maintenance and monitoring of tenant eligibility documentation in the Section 8 New Construction and Substantial Rehabilitation Program to ensure that established internal control policies are being followed on a timely basis. Management’s corrective action plan will include enhanced file review procedures and staff training. Donald Grondahl, Executive Director, is responsible for implementing this corrective action by December 31, 2026.