Finding Text
2025-001 ALN 14.872 – Public Housing Capital Fund Program – Period of Performance Condition and Criteria: Capital Funds transferred to operations (BLI 1406) are not considered obligated until the PHA has budgeted and drawn down the funds. The voucher request date must occur before those funds are reported as obligated in LOCCS under the Obligation & Expenditure tab (24 CFR section 905.314(1). The Authority has internal control deficiencies over CFP period of performance as they did not draw down BLI 1406 funds before the obligation end date. Amount of Questioned Costs: $395,233 Context: The Authority reported two drawdowns in eLOCCS from BLI 1406 prior to the obligation deadlines in 2023; however, the associated funds were not actually drawn down until 2025 Cause: The PHA did not align eLOCCS reporting with actual cash management practices, leading to early drawdown reporting relative to fund disbursement. Possible contributing factors include insufficient internal controls over eLOCCS entries or inadequate staff training on drawdown timing requirements. Effect: Obligating funds from BLI 1406 before the drawdown creates a compliance deviation and exposes the agency to potential audit findings, risk of questioned costs, and misalignment with HUD cash management regulations. This may affect the PHA’s PHAS scoring under the financial condition indicator if similar deficiencies persist. Auditor’s Recommendation: Ensure that all future eLOCCS drawdowns reflect actual cash requirements in accordance with 24 CFR § 905.314(l), implement internal control procedures to verify the timing of drawdowns relative to obligations and actual payments, and periodically review drawdown and expenditure records to proactively identify and correct discrepancies. Grantee Response: The Authority has agreed to follow the auditor’s recommendation to ensure management stays on top of period of performance dates and cash management procedures by attending regular training sessions and performing reviews of CFP reporting documents to maintain compliance.