Finding 43980 (2022-001)

Significant Deficiency Repeat Finding
Requirement
A
Questioned Costs
-
Year
2022
Accepted
2023-09-29

AI Summary

  • Core Issue: Low Rent Public Housing funds were potentially used for unallowable expenses, violating compliance requirements.
  • Impacted Requirements: The Authority must ensure timely reconciliation of interfund balances to avoid using federal funds for nonfederal programs.
  • Recommended Follow-Up: Implement monthly reconciliations and establish controls to limit interfund transactions without guaranteed reimbursement.

Finding Text

Finding No. 2022-001 Low Rent Public Housing, CFDA #14.850 Compliance Requirement: Activities Allowed or Unallowed Type of Finding: Noncompliance, Significant Deficiency Condition Testing of interfund receivable balances owed to the Low Rent Public Housing (LRPH) program from the State and Local program indicated potential unallowable uses of LRPH grant funds. Criteria The Operating Fund is designed to make financial assistance available to PHA's for the operation and management of public housing. The use of a centralized revolving fund allows the use of one program's cash to cover expenses of another program which is subsequently reimbursed within a reasonable amount of time. Inter-program due to and due from balances, not reconciled on a timely basis, indicate the existence of temporary loans and are unallowable. Cause The State and Local and Business Activities programs have not generated sufficient cash required to reimburse the revolving fund for expenses incurred on its behalf before the end of the operating cycle. Effect It appears LRPH funds in the amount of $4,187,205 were used to cover development costs of nonfederal programs. This is considered an unallowable use of grant funds and may be subject to repayment. Context The Authority is not in compliance regarding loaning federal funds to nonfederal programs. Questioned Costs N/A Recommendation We recommend the Authority reconcile and settle interfund balances on a monthly basis. In addition, we recommend the Authority establish controls to restrict interfund transactions for which there is no certainty of reimbursement before the accounting period cut-off.

Corrective Action Plan

Finding No. 2022-001 Authority?s Response and Corrective Action Plan The Authority had planned on receiving developer fees and predevelopment reimbursements related to the construction activities in an amount in excess of the interfund balance noted in the finding. There have been repeated delays to several projects which have delayed the receipt of predevelopment reimbursements and fees which led to the majority of the interfund issue. The Executive Director deals are coming to fruition in Quarters 3 and 4 of FY2023. The Bristol Schools Project final construction closing is scheduled for 10/15/2023-11/1/2023 which will result in full repayment of FY2022 receivable. The MRC will also earn fees from the performing project. The MHA has issued two bonds for Redevelopment valued for $128 million that will reimburse the MHA and MRC for all outstanding receivables related to Energy Improvements, Yale Acres Community Center, 143 West Main Street and Hanover Place. The closing for these bonds is scheduled for November 16, 2023. Following this planned extinguishing of redevelopment receivables, the Executive Team is now updating the interfund policy to require the reconciliation and settling of interfund balance on a monthly basis and determining a reasonable dollar value for that policy. Person Responsible for Corrective Action Contact; Robert Cappelletti, Executive Director, rcappelletti@meriden-ha.com

Categories

Cash Management HUD Housing Programs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 43981 2022-002
    Significant Deficiency
  • 43982 2022-003
    Significant Deficiency
  • 43983 2022-004
    Significant Deficiency
  • 43984 2022-003
    Significant Deficiency
  • 43985 2022-004
    Significant Deficiency
  • 620422 2022-001
    Significant Deficiency Repeat
  • 620423 2022-002
    Significant Deficiency
  • 620424 2022-003
    Significant Deficiency
  • 620425 2022-004
    Significant Deficiency
  • 620426 2022-003
    Significant Deficiency
  • 620427 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $11.51M
14.850 Public and Indian Housing $1.53M
14.872 Public Housing Capital Fund $547,604
14.870 Resident Opportunity and Supportive Services - Service Coordinators $516,604
14.879 Mainstream Vouchers $295,250