Finding 561167 (2022-002)

Finding Number: 2022-002 Finding Type: Federal award finding and financial statement finding Federal Assistance Listing No.: 14.239 Program Name: HOME investment Partnership Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Portland Housing Bureau Grant Numbers: 311020 Federal Award Year: 2022 Control Deficiency Type: Significant deficiency in internal controls over compliance Instance of Noncompliance: Yes Compliance Requirement: Reporting Questioned Costs: None Repeat Finding: 2021-002 Criteria: In accordance with the requirements of CFR §200.512, the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report, or nine months after the end of the audit period. Condition: PCRI did not electronically submit its December 31, 2022 Single Audit reporting package to the Federal Clearinghouse within the required time period. Cause: The organization’s 2022 accounting records were not closed in a timely matter and the audit was not completed prior to the data collection form due date. Effect: PCRI did not comply with CFR §200.512. The late submission results in non-compliance for all federal programs. Audit Recommendation: We recommend that management implement procedures to ensure that all required reporting is submitted in a timely manner and in accordance with CFR §200.512 deadlines. Management’s Response: As has been addressed earlier in management’s response to Finding 2022-001, PCRI had created and filled two new positions in the Fiscal Department the Controller and an additional Staff Accountant. The additional staff led to better internal controls and more timely reconciliations throughout 2022. Notwithstanding these efforts, time was needed to train personnel on PCRI systems and emphasis was put on the completion of the subsidiary audits for King Parks Apartments Limited Partnership and MLK & Cook Apartments Limited Partnerships, which are an integral part of the consolidated PCRI audit report, in the early months of 2022 leading to the noted delay in reconciliations for the PCRI audit. In addition to these delays, PCRI once again experienced turnover in the added Staff Accountant position in June of 2023, leading to delays and the employee in the Controller position went on an extended medical leave and subsequently ended employment with PCRI, leading to further delays. Further contributing to delays was the turnover of accounting staff at the property management company with whom PCRI contracts for management of the Maya Angelou and Park Terrace properties which lead to delays in starting those audit engagements which are integral to the consolidated PCRI audit report. In response to this cycle of staff turnover, PCRI contracted with an external service to fill the Staff Accountant position while the search for a permanent employee to fill the position continues to this day, and PCRI has subsequently hired a well-qualified person as Fiscal Director. The property manager for the Maya Angelou and Park Terrace properties has also taken steps to stabilize their accounting operations. These responses have mitigated the risk of delay of future audits as the additional personnel hired in response to the 2021 finding was effective were it not for the untimely turnover of staff during the time when the 2022 PCRI audit was being prepared for and conducted.