Finding Text
Finding 2022-001 Information on Federal Program. ALN 14.872 ? Public Housing Capital Fund Program Type of Finding. Non-compliance and significant deficiency in internal controls over compliance. Compliance Requirement. Allowable Activities and Allowable Costs Criteria. Pursuant to 24 CFR 905.200 eligible activities for the CFP ?? include the development, financing, and modernization of public housing projects, including the redesign, reconstruction, and reconfiguration of public housing sites and buildings (including compliance with the accessible design and construction requirements contained in 24 CFR 8.32, 24 CFR part 40, 24 CFR part 100, 28 CFR 35.151, and 28 CFR part 36, as applicable) and the development of mixed finance projects?.? Condition. The auditor noted that the Authority charged indirect administrative costs to CFP funds designated for General Capital Activity (Budget Line Item (BLI) 1480), including costs for telephone, internet, and fuel. Cause. Management was unaware that such costs could not be charged to CFP fund earmarked for General Capital Activity. Effect. Potential effects of using these funds for ineligible activities and not knowing what is and is not eligible include: (1) Compliance issues: The Department of Housing and Urban Development (HUD) requires strict compliance with the use of capital fund program monies. If an organization uses these funds for ineligible activities, it may face compliance issues and risk losing future funding; (2) Financial penalties: HUD may impose financial penalties on an organization that uses capital fund program monies for ineligible activities. These penalties can be significant and can have a negative impact on an organization's financial stability; (3) Legal action: In some cases, using capital fund program monies for ineligible activities may result in legal action being taken against the organization; (4) Negative impact on the community: If capital fund program monies are not used for eligible activities, it can have a negative impact on the community that the organization serves. For example, if funds are used for administrative expenses instead of repairs or renovations, residents may have to live in unsafe or unsanitary conditions; and (5) Loss of trust: Using capital fund program monies for ineligible activities can damage an organization's reputation and erode the trust of the people it serves. This can make it more difficult to secure future funding or support from the community. Questioned Costs. Not determinable. Context. The auditor selected a sample of 8 payment vouchers charged to BLI 1480 totaling $302,510 (or 61%) for examination of the 21 total payment vouchers totaling $497,617. All payment vouchers examined included ineligible costs charged to CFP. Recommendation. To address this issue, the auditor recommends the following for correcting this issue: (1) Conduct an internal review: The housing authority should conduct a thorough internal review to identify any improper use of capital fund program monies. This review should include a detailed analysis of all financial transactions related to these funds; (2) The housing authority should contact HUD to seek guidance on how to correct any issues related to the improper use of capital fund program monies. HUD can provide information on how to return the funds if needed, make appropriate corrections, and avoid future compliance issues; (3) Develop a corrective action plan: Based on the findings of the internal review and guidance from HUD, the housing authority should develop a corrective action plan to address any issues related to the improper use of capital fund program monies. This plan should include specific steps for returning any misused funds, making appropriate corrections, and ensuring future compliance with HUD regulations; (4) Communicate with stakeholders: The housing authority should communicate openly and transparently with stakeholders, including residents, board members, and community partners, about the corrective action plan and the steps being taken to address any issues related to the improper use of capital fund program monies. This can help to rebuild trust and maintain support for the organization; and (5) Implement controls and training: To prevent future compliance issues, the housing authority should implement controls and training to ensure that all staff members understand the eligibility requirements for capital fund program monies and are trained on how to properly use these funds. This can include regular training sessions, internal audits, and ongoing monitoring of financial transactions. Views of Responsible Officials. Management agrees.