Finding 1223540 (2025-002)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2025
Accepted
2026-07-10

AI Summary

  • Core Issue: Expenses were misallocated across projects due to a centralized operating account and lack of controls.
  • Impacted Requirements: This violates HUD guidelines requiring accurate project accounting and proper expense allocation.
  • Recommended Follow-Up: Strengthen internal controls, implement supervisory reviews, and correct past misallocations.

Finding Text

Condition: Management utilizes a centralized operating account to process transactions. During our audit, we identified multiple instances in which expenses were not allocated to the appropriate project. Certain costs were charged to the wrong entity and, in some cases, were recorded to projects that did not benefit from the expenditure. The misallocations occurred across multiple fiscal years. Criteria: HUD Handbook 4370.2, Financial Operations and Accounting Procedures for Insured Multifamily Projects, requires that each project maintain accounting records that accurately reflect its own financial activity. Costs must be charged to the specific project that receives the direct benefit, and shared expenses must be allocated using a reasonable, supportable, and consistently applied methodology. HUD also requires that project funds be used solely for the operation of the project to which they relate. Cause: The centralized operating account structure, combined with insufficient controls over transaction coding and allocation, resulted in errors in assigning expenses to the correct project. Management did not consistently review or reconcile postings to ensure that costs were properly allocated. Effect: Misallocation of expenses can distort the financial position and operating results of individual projects. This may result in inaccurate reporting to HUD, potential improper use of project funds, difficulty assessing each project's true financial performance, and an increased risk of noncompliance with HUD program requirements. Questioned Costs: $156 Auditor's Recommendation: We recommend that management strengthen internal controls over the allocation and recording of expenses, including a) Requiring supervisory review of all centralized account postings, b) Performing periodic reconciliations to ensure expenses are charged to the correct project, and c) Correcting prior year misallocations where appropriate. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding related to the misallocation of some expenses among projects. The issue resulted from errors in address based allocation, which have since been corrected. Although the impact of these misallocations was not material to the overall financial statements, we recognize the importance of accurate project level reporting in accordance with HUD requirements. Corrective actions have been implemented, including correcting address assignments, enhancing supervisory review of transactions, and performing periodic reconciliations. Management will continue to monitor expenses to ensure they are consistently allocated to the appropriate project. Adjustments to correct prior misallocations will be made during fiscal year 2026. Management remains committed to maintaining compliance with HUD requirements and ensuring the accuracy of each project’s financial records.

Corrective Action Plan

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

Categories

HUD Housing Programs Reporting Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1223539 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.181 SUPPORTIVE HOUSING FOR PERSONS WITH DISABILITIES $55,180