Finding 375531 (2023-004)

Material Weakness
Requirement
AHN
Questioned Costs
$1
Year
2023
Accepted
2024-03-11

AI Summary

  • Core Issue: The Authority mismanaged $206,189.50 in Capital Fund grant expenditures, with many costs deemed unallowable due to improper budgeting and reporting.
  • Impacted Requirements: The Authority failed to meet the 90% obligation threshold within the required 24 months and inaccurately reported grant obligations and expenditures in LOCCS.
  • Recommended Follow-Up: Implement procedures for regular grant status updates at board meetings, ensure all obligations are backed by contracts, and consult with HUD to address compliance issues.

Finding Text

Finding 2023-004: Capital Fund Grant Administration Capital Funds 14.872 Material Weakness/Noncompliance – Activities Allowed or Unallowed, Period of Performance, Special Tests and Provisions Questioned Costs: $206,189.50 Criteria: The Authority is awarded an annual Capital Fund grant each year. The Authority prepares a five-year plan which indicates improvements the grants will be used for and the dollar amount. This annual budget is modified upon the grant award to match the grant amount. Only items included within the budget are allowable costs. Unless an extension is approved by HUD, the Authority must obligate at least 90 percent of each Capital Fund grant within 24 months of the funds becoming available to the Authority for obligation. The Authority is required to self-report obligations and expenditures in the Line of Credit Control (LOCCS) monthly. Condition: During our audit, we tested $240,034.30 of the $252,818.56 of Capital Fund grant transactions. Of the $240,034.30 tested, $173,832.14 of expenditures were not included as work items in the applicable grant budget and therefore not allowable. The Authority was required to meet the 90% obligation threshold by May 28, 2022 for the 2018 Capital Fund grant. The Authority had reported either 100% or 98% obligation since the Authority began reporting in LOCCS for the period of May, 2018. We noted $32,357.36 of expenditures related to the 2018 Capital Fund grant that were associated with a contract signed on July 1, 2022 which is after the obligation deadline. Based on the actual obligation occurring after the obligation deadline and the fact the Authority reported the grant fully obligated since May, 2018, these expenditures are also not allowable. We further noted a variety of issues with the Authority’s reporting of funds obligated and expended in LOCCS. Specifically, we noted the following: • As noted above, the Authority reported the 2018 grant as fully obligated when it had signed a contract for the work after the obligation deadline. • The Authority entered into a contract on January 11, 2022 for work related to the 2019 Capital Fund grant. The Authority did not adjust the obligation amount in LOCCS for this until October, 2022. The Authority had expended $160,055.23 of the grant as of June 30, 2023 but the Authority was still reporting the balance at $108,517.03 reported for the June, 2022 period in ELOCCS on in the November, 2023 report as the report had not been updated. The $108,517.03 reconciled to the June 30, 2022 general ledger balance. • Related to the 2021 Capital Fund grant, the Authority entered into a contract on January 11, 2022, however, the amount reported as obligated in LOCCS did not change until the January, 2023 reporting period. • Related to the 2022 Capital Fund grant, the Authority reported a $57,030.14 increase in the amount reported obligated for the period ending October, 2022. We inquired of the Executive Director of what made up the obligation and she was unable to identify the obligation. It should be noted that due to the limited staff, compliance with the Capital Fund grant requirements was solely with responsibility of the Executive Director without compensating controls. Cause: The responsibility to administer Capital Fund grant was the responsibility of one individual and the staff did not have a proper understanding of how the Capital Fund grant was to operate and was unaware of the various rules and regulations. The Executive Director was under the assumption that as long as a cost was in the five-year plan, the Authority could spend any of its grants on the item. Further, the Authority had gotten away from maintaining subsidy recorded to support grant funds obligated and expended by grant. Effect or Potential Effect: $206,189.50, or 82%, of capital fund grant expenditures during the year are being questioned as unallowed activities. Further, the reporting of funds obligated and expended were materially in error. Based on the level of noncompliance noted, we have issued an adverse opinion of Capital Fund grant compliance. Recommendation: During our audit fieldwork, the Executive Director indicated she had recently received Capital Fund grant training and had realized she had not administered the grant correctly. The Authority should establish procedures to report at board meetings the status of the grants including the grant award, obligation and expenditure deadlines, funds obligated, funds advanced and funds expended. All obligations should be supported by signed contracts or invoices/billings. The Authority should review this situation with HUD to determine how to remedy it. View of the Responsible Officials of the Auditee: The auditee’s management agrees with the finding.

Corrective Action Plan

Finding 2023-004: Capital Fund Grant Admin NHA Corrective Action: The Authority has all documentation on paper for all payment vouchers, statements that monies were drawn down correctly, invoices, and records of payments. The updated annual online budget forms were not completed in the required Capital Funds timeline regulations. Plans are underway to update the 2023 online budgets within the next month. Ongoing Capital Funds Education continues to be prioritized. Improvements in internal processes will be implemented as knowledge is accumulated. When these online budgets are updated with the information from the paper tracking documentation and submitted for approval to the regional office, it will be clear that the $206,189.50 in Questioned Costs in this finding were accurately distributed. In order to prevent this situation from occurring in the future, the Authority will follow the finding recommendation to provide the following reports at monthly board meetings beginning with the April 2024 board meeting.: • status of grants including grant award • obligation and expenditure deadlines • funds obligated • funds advance, and • funds expended

Categories

Questioned Costs Special Tests & Provisions Allowable Costs / Cost Principles HUD Housing Programs Material Weakness Period of Performance Reporting

Other Findings in this Audit

  • 375529 2023-003
    Material Weakness Repeat
  • 375530 2023-003
    - Repeat
  • 375532 2023-005
    Material Weakness
  • 375533 2023-006
    Material Weakness
  • 951971 2023-003
    Material Weakness Repeat
  • 951972 2023-003
    - Repeat
  • 951973 2023-004
    Material Weakness
  • 951974 2023-005
    Material Weakness
  • 951975 2023-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $375,523
14.850 Public and Indian Housing $360,784
14.872 Public Housing Capital Fund $252,819