Finding Text
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Public and Indian Housing Assistance Listing Numbers: 14.850 Award Period: 1/1/2022-12/31/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: The Utility Expense Level (UEL) is used to calculate the utility portion of the Operating Fund subsidy. This compliance supplement requires testing of rolling base data. PHAs must retain such data pursuant to 990.325. PHAs receive invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to the Form 52722. The auditors should perform a random sample of each of the main utility types (gas, water/sewer, electric, etc.) to review accuracy of the unit of measure, consumption and cost data reported on Form 52722. Condition: During our testing, we noted that consumption levels and actual utility costs did not agree to the utility tracker for one property. Questioned Costs: $43,948 Content: During our testing, we noted one asset management project (AMP) that had a gas consumption level per the HUD-52722 that did not agree to the utility tracker maintained by the Authority. For this same AMP, the actual utility costs for water/sewer, gas and electricity did not agree to the totals per the utility tracker. Cause: The Authority did not consistently ensure that utility consumption and cost data reported on Form HUD-52722 agreed to the supporting utility tracking records. During the audit period, the Authority was continuing to recover from operational disruptions caused by the COVID-19 public health emergency and experienced significant staff turnover. As responsibilities were reassigned and new personnel assumed utility reporting duties, a data entry error occurred for one AMP, resulting in utility consumption and cost information being reported incorrectly. The Authority acknowledges that its review procedures were not sufficient to detect and correct the error before submission. Effect: The Authority is not providing accurate data to HUD regarding utility costs and usage, and the Authority is not in compliance with HUD regulations. Repeat Finding: No Recommendation: We recommend that management review their procedures for tracking utility costs and usage in order to accurately complete the HUD-52722 form. Views of Responsible Officials: The Authority concurs with this finding and acknowledges that utility consumption and cost data for one AMP was reported incorrectly on Form HUD-52722. During the audit period, the Authority was continuing to address the operational impacts of the COVID- 19 public health emergency while also experiencing significant staff turnover. As key responsibilities were transitioned to new personnel, a data entry error occurred during the preparation of the utility reporting information for one AMP. The Authority recognizes that its internal review process should have identified this discrepancy prior to submission. The Authority accepts responsibility for this deficiency and has taken corrective action to strengthen its internal controls over utility reporting. Management has implemented additional supervisory review procedures requiring reported utility data to be reconciled to the supporting utility tracker before submission. In addition, staff responsible for preparing and reviewing Form HUD-52722 have received additional training on utility reporting requirements and data verification procedures. These measures are intended to improve the accuracy of utility reporting and help ensure compliance with HUD requirements in future reporting periods.