Finding 1237542 (2024-004)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2026-09-28

AI Summary

  • Core Issue: The Authority lacks adequate documentation and approval for interfund transactions, leading to material weaknesses in internal controls and noncompliance with federal regulations.
  • Impacted Requirements: Compliance with 2 CFR sections 200.302 and 200.303 is critical for accurate financial reporting and safeguarding federal funds, which the Authority has failed to meet.
  • Recommended Follow-Up: Management should establish processes for tracking interfund transactions and designate a responsible individual for oversight, while also initiating reimbursements to affected programs.

Finding Text

Interfund Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster and Public Housing Operating Fund Assistance Listing Number: 14.871;14.879 and 14.850 Federal Award Identification Number and Year: FL007, 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Authority must ensure that all financial transactions, including interfund activity, are recorded accurately, supported by documentation, and compliant with federal financial management requirements. Under 2 CFR section 200.302, the Authority is required to maintain financial management systems that provide for accurate, current, and complete disclosure of financial results for all federally assisted programs. In addition, 2 CFR section 200.303 requires the Authority to implement internal controls to safeguard federal funds and ensure that transactions are properly authorized and recorded. Interfund loans, transfers, and reimbursements must be supported by adequate documentation, consistent with the Authority’s cost allocation plan, and compliant with the cost principles in 2 CFR part 200, subpart E. Costs charged to the Housing Choice Voucher (HCV) Program or Public Housing Program must be allowable, reasonable, necessary, and allocable under 2 CFR section 200.405. Any temporary use of HCV or Public Housing funds for non HCV purposes, or vice versa, must be fully documented and promptly reimbursed to the benefiting program. PHAs must also maintain complete and accurate accounts and records for all program transactions in accordance with 24 CFR section 982.158(a). The PHA must ensure that all interfund transactions are timely reconciled, supported by appropriate documentation, and accurately reflected in the PHA’s financial statements and HUD reporting systems, including the Financial Data Schedule (FDS) submitted under 24 CFR part 5, subpart H. Condition: During the audit, interfund transactions between program funds were identified, which lacked adequate documentation and approval. The Authority could not provide support for the interfund balance transfers and reimbursements between the programs. Questioned costs: $5,660,183 (ALN 14.850); $1,714,685 (ALN 14.871); $82,702 (ALN 14.879); $67,870 (ALN 14.EHV) Context: The Authority is not in compliance with federal regulations regarding transfers of operating funds and maintaining adequate documents per the compliance requirements. Cause: The Authority does not have adequate internal controls designed to ensure that requirements were being met. Effect: The Authority does not have proper controls over the reporting process. Repeat Finding: Yes 2024 – 004 – Interfund Recommendation: We recommend management should create processes to track interfunds and transfers as well as designate an individual to review and approve these transactions. Additionally, the Authority should begin the process of reimbursing the respective programs. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Interfund Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Public Housing Operating Fund – Assistance Listing No. 14.850 Recommendation: We recommend management should create processes to track interfunds and transfers as well as designate an individual to review and approve these transactions. Additionally, the Authority should begin the process of reimbursing the respective programs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2025, the HA hired the financial consulting firm of Kubas Keller and Associates. They have vast experience with HA’s all around the country and will work with staff and possibly a new CFO to ensure if interfunds and transfers are properly tracked and eliminated on the financials. This includes reviewing past transactions and correcting them in FY 2026. Name(s) of the contact person(s) responsible for corrective action: Tony Palmer, CPA Kubas Keller and Associates Planned completion date for corrective action plan: June 2026.

Categories

HUD Housing Programs Allowable Costs / Cost Principles Cash Management

Other Findings in this Audit

  • 1237533 2024-002
    Material Weakness Repeat
  • 1237534 2024-002
    Material Weakness Repeat
  • 1237535 2024-002
    Material Weakness Repeat
  • 1237536 2024-003
    Material Weakness Repeat
  • 1237537 2024-003
    Material Weakness Repeat
  • 1237538 2024-003
    Material Weakness Repeat
  • 1237539 2024-004
    Material Weakness Repeat
  • 1237540 2024-004
    Material Weakness Repeat
  • 1237541 2024-004
    Material Weakness Repeat
  • 1237543 2024-005
    Material Weakness Repeat
  • 1237544 2024-005
    Material Weakness Repeat
  • 1237545 2024-005
    Material Weakness Repeat
  • 1237546 2024-006
    Material Weakness Repeat
  • 1237547 2024-006
    Material Weakness Repeat
  • 1237548 2024-006
    Material Weakness Repeat
  • 1237549 2024-007
    Material Weakness Repeat
  • 1237550 2024-007
    Material Weakness Repeat
  • 1237551 2024-007
    Material Weakness Repeat
  • 1237552 2024-008
    Material Weakness Repeat
  • 1237553 2024-009
    Material Weakness Repeat
  • 1237554 2024-009
    Material Weakness Repeat
  • 1237555 2024-009
    Material Weakness Repeat
  • 1237556 2024-009
    Material Weakness Repeat
  • 1237557 2024-010
    Material Weakness Repeat
  • 1237558 2024-010
    Material Weakness Repeat
  • 1237559 2024-010
    Material Weakness Repeat
  • 1237560 2024-011
    Material Weakness Repeat
  • 1237561 2024-012
    Material Weakness Repeat
  • 1237562 2024-013
    Material Weakness Repeat
  • 1237563 2024-013
    Material Weakness Repeat
  • 1237564 2024-013
    Material Weakness Repeat
  • 1237565 2024-013
    Material Weakness Repeat
  • 1237566 2024-014
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.850 PUBLIC HOUSING OPERATING FUND $2.90M
14.875 PUBLIC HOUSING NEIGHBORHOOD NETWORKS GRANTS $1.92M
14.879 MAINSTREAM VOUCHERS $1.47M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $311,302
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $91,537
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $90,248
14.895 JOBS-PLUS PILOT INITIATIVE $83,763
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $10,478