Finding Text
2023-001 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission
Public and Indian Housing Program – CFDA Number 14.850
Section 8 Housing Choice Vouchers Program – CFDA Number 14.871
Mainstream Vouchers – CFDA Number 14.879
Material Weakness in Internal Control and Material Noncompliance
This is a repeat finding of 2022-002 from March 31, 2022 (initially occurred as Finding 2020-002 from March 31, 2020)
Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended).
Condition: The Authority’s original unaudited FDS filing reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024.
Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover.
Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding.
Questioned Cost: None
Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely.
Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.