Finding 1228925 (2024-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2026-09-04
Audit: 410443
Organization: Comhar, Inc. and Affiliates (PA)

AI Summary

  • Core Issue: The Group failed to make required monthly deposits to the replacement reserve accounts for HUD projects, instead opting for lump sum deposits.
  • Impacted Requirements: This non-compliance with HUD Regulatory Agreements jeopardizes adherence to federal guidelines regarding replacement reserve funds.
  • Recommended Follow-Up: Implement internal controls and conduct monthly reviews to ensure timely and accurate deposits moving forward.

Finding Text

Finding 2024-001 - Replacement Reserve Deposits Assistance Listing Number: 14.157 Program Name: Supporting Housing for the Elderly (HUD) Federal Agency: U.S. Department of Housing and Urban Development Federal Award Year: July 1, 2023 – June 30, 2024 Criteria: The provision of the HUD Regulatory Agreements require the Group establish and maintain replacement reserve funds for each project in a separate interest-bearing bank account and deposit an identical amount on a monthly basis, as stated in each project’s most recent HUD 9250 which includes any changes in monthly deposits. Condition and Context: During the testing performed over the five HUD projects and related replacement reserve required monthly deposits, we noted that lump sum deposits for each project were made during the months of October and November to the replacement reserve account instead of monthly deposits being made, as required by HUD. In addition, we noted that the total annual deposit to the replacement reserve for one project was under deposited by $23. Effect or Potential Effect: The Group is not in compliance with HUD Regulatory Agreements. Cause: Administrative oversight on the part of the Group's management resulted in the items noted above. Questioned Costs: None Recommendations: We recommend the Group comply with their HUD Regulatory Agreements and implement appropriate processes and internal controls, including an independent monthly review, to identify the correct monthly replacement reserve amount for each project and make those deposits monthly in accordance with federal requirements. View of Responsible Officials: The Group agrees with this finding. The retroactive deposit for underpayment to the replacement reserve was deposited and monthly deposits are being made monthly and has been since remediated.

Corrective Action Plan

Subject: Compliance with HUD Replacement Reserve Monthly Deposit Requirement Issue Identified: HUD regulations require that deposits into the Replacement Reserve account be made on a monthly basis. Our agency has historically made annual lump-sum deposits, which is not in compliance with HUD guidelines. Corrective Actions 1. Change in Deposit Frequency Action: Transition from an annual deposit schedule to a monthly deposit schedule in accordance with HUD requirements. Responsible Party: CFO and Accounting Manager Timeline: Effective May 1, 2025, monthly deposits will begin. Verification: Monthly entries and bank confirmations will be reviewed by Accounting. 2. Implementation of Automated Transfers Action: Establish and schedule automated monthly bank transfers to the Replacement Reserve account. Responsible Party: Accounting Manager in collaboration with Banking Institution Timeline: Setup completed by 04/15/2025. First automated transfer on 05/01/2025. Verification: Confirmation of automation setup from the bank and successful execution of first transfer. 3. Monthly Notifications to Fiscal Personnel Action: Create an automated monthly email notification system to alert key fiscal personnel of each deposit, including the amount and confirmation of receipt. Responsible Party: Budget & Reimbursement Manager Timeline: Notification system live by 05/01/2025. Verification: Email log confirming monthly communications sent to fiscal team. Ongoing Monitoring and Compliance The Accounting Manager will review monthly bank statements to verify timely and accurate deposits. The Controller will incorporate verification into monthly closing procedures.

Categories

Internal Control / Segregation of Duties HUD Housing Programs

Other Findings in this Audit

  • 1228921 2024-001
    Material Weakness Repeat
  • 1228922 2024-001
    Material Weakness Repeat
  • 1228923 2024-001
    Material Weakness Repeat
  • 1228924 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.778 GRANTS TO STATES FOR MEDICAID $846,041
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $700,000
93.829 SECTION 223 DEMONSTRATION PROGRAMS TO IMPROVE COMMUNITY MENTAL HEALTH SERVICES $550,000
14.235 SUPPORTIVE HOUSING PROGRAM $501,640
14.157 SUPPORTIVE HOUSING FOR THE ELDERLY $80,621
93.667 SOCIAL SERVICES BLOCK GRANT $56,194
14.195 PROJECT-BASED RENTAL ASSISTANCE (PBRA) $44,820