FAC Explorer

Finding 1222356 (2025-004)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-06-30
Audit: 406137
Organization: City of Amarillo, Texas (TX)
Auditor: CLIFTONLARSONALLEN LLP

AI Summary

  • Core Issue: The City of Amarillo issued a housing assistance payment without completing the required rent reasonableness determination.
  • Impacted Requirements: This violates 24 CFR 982.507(a)(1), which mandates that rent must be deemed reasonable before lease approval and HAP contract execution.
  • Recommended Follow-Up: Strengthen internal controls by implementing checklists, supervisory reviews, and staff training to ensure compliance with rent reasonableness determinations.

Finding Text

Special Test – Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster ALN: 14.871 14.879 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: October 1, 2024 – September 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), the City of Amarillo (the City) must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 24 CFR 982.507(a)(1), the City must determine that the rent to owner is reasonable prior to approving the lease and executing the HAP contract; therefore, housing assistance payments should not be made before a rent reasonableness determination is completed. Condition: For one of 40 samples tested, the City issued a housing assistance payment before completing and documenting the required rent reasonableness determination. As a result, the City did not demonstrate compliance with Housing Choice Voucher program requirements requiring rent reasonableness to be determined prior to approval of the lease and execution of the HAP contract. Questioned costs: None. Context: See “Condition.” Cause: The City did not have sufficient control procedures in place to ensure rent reasonableness determinations were completed, documented, and reviewed before housing assistance payments were issued. Effect: Failure to complete rent reasonableness determinations prior to payment increases the risk that housing assistance payments may be made for units with rents that are not properly supported as reasonable, which could result in improper payments and noncompliance with Housing Choice Voucher program requirements. Repeat Finding: No. Recommendation: The City should strengthen controls over the lease-up and payment process to ensure rent reasonableness determinations are completed, documented, and reviewed before lease approval, HAP contract execution, and issuance of housing assistance payments. This may include using a formal checklist or workflow control, requiring supervisory review, and providing staff training on program requirements. Views of responsible officials: See management response on corrective action plan.

Corrective Action Plan

Finding 2025-004: Special Test – Reasonable Rent Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: The City will determine that the rent to owner is reasonable prior to approving the lease and executing the HAP contract. Implementation dates: September 30, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer

Categories

HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 1222348 2025-002
    Material Weakness Repeat
  • 1222349 2025-002
    Material Weakness Repeat
  • 1222350 2025-002
    Material Weakness Repeat
  • 1222351 2025-003
    Material Weakness Repeat
  • 1222352 2025-003
    Material Weakness Repeat
  • 1222353 2025-003
    Material Weakness Repeat
  • 1222354 2025-004
    Material Weakness Repeat
  • 1222355 2025-004
    Material Weakness Repeat
  • 1222357 2025-005
    Material Weakness Repeat
  • 1222358 2025-005
    Material Weakness Repeat
  • 1222359 2025-005
    Material Weakness Repeat
  • 1222360 2025-006
    Material Weakness Repeat
  • 1222361 2025-006
    Material Weakness Repeat
  • 1222362 2025-006
    Material Weakness Repeat
  • 1222363 2025-006
    Material Weakness Repeat
  • 1222364 2025-006
    Material Weakness Repeat
  • 1222365 2025-006
    Material Weakness Repeat
  • 1222366 2025-007
    Material Weakness Repeat
  • 1222367 2025-007
    Material Weakness Repeat
  • 1222368 2025-007
    Material Weakness Repeat
  • 1222369 2025-007
    Material Weakness Repeat
  • 1222370 2025-007
    Material Weakness Repeat
  • 1222371 2025-007
    Material Weakness Repeat
  • 1222372 2025-008
    Material Weakness Repeat
  • 1222373 2025-008
    Material Weakness Repeat
  • 1222374 2025-008
    Material Weakness Repeat
  • 1222375 2025-008
    Material Weakness Repeat
  • 1222376 2025-008
    Material Weakness Repeat
  • 1222377 2025-008
    Material Weakness Repeat
  • 1222378 2025-009
    Material Weakness Repeat
  • 1222379 2025-010
    Material Weakness Repeat
  • 1222380 2025-010
    Material Weakness Repeat
  • 1222381 2025-010
    Material Weakness Repeat
  • 1222382 2025-010
    Material Weakness Repeat
  • 1222383 2025-010
    Material Weakness Repeat
  • 1222384 2025-010
    Material Weakness Repeat
  • 1222385 2025-010
    Material Weakness Repeat
  • 1222386 2025-010
    Material Weakness Repeat
  • 1222387 2025-010
    Material Weakness Repeat
  • 1222388 2025-010
    Material Weakness Repeat
  • 1222389 2025-010
    Material Weakness Repeat
  • 1222390 2025-010
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
66.458 CLEAN WATER STATE REVOLVING FUND $8.51M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.86M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $1.65M
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $1.08M
97.083 STAFFING FOR ADEQUATE FIRE AND EMERGENCY RESPONSE (SAFER) $1.06M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $461,479
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $446,457
16.922 EQUITABLE SHARING PROGRAM $368,477
93.977 SEXUALLY TRANSMITTED DISEASES (STD) PREVENTION AND CONTROL GRANTS $290,077
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $278,792
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $266,635
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $251,804
14.879 MAINSTREAM VOUCHERS $238,045
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $220,211
81.214 ENVIRONMENTAL MONITORING/CLEANUP, CULTURAL AND RESOURCE MGMT., EMERGENCY RESPONSE RESEARCH, OUTREACH, TECHNICAL ANALYSIS $207,307
20.219 RECREATIONAL TRAILS PROGRAM $180,400
20.939 SAFE STREETS AND ROADS FOR ALL $172,088
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $151,387
93.940 HIV PREVENTION AND SURVEILLANCE ACTIVITIES-HEALTH DEPARTMENT BASED $125,000
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $112,919
93.778 GRANTS TO STATES FOR MEDICAID $79,886
20.507 FEDERAL TRANSIT FORMULA GRANTS $66,531
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $55,561
16.609 PROJECT SAFE NEIGHBORHOODS $51,000
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $43,974
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $40,331
87.002 VIRGINIA GRAEME BAKER POOL AND SPA SAFETY $32,932
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $27,607
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $21,960
20.526 BUSES AND BUS FACILITIES FORMULA, COMPETITIVE, AND LOW OR NO EMISSIONS PROGRAMS $20,819
14.267 CONTINUUM OF CARE PROGRAM $18,815
97.067 HOMELAND SECURITY GRANT PROGRAM $16,029
45.310 GRANTS TO STATES $11,124
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $10,441
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $8,441
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $0
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $0
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $0