EIN: 042401810
UEI: TZ1ATLETJV93
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 23, 2021. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by November 23, 2021 (1733 days ago).
What is a management decision? →2020-001 ? Eligibility: Rent Calculation Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Voucher Cluster CRITERIA The PHA is responsible for reexamination and verification of income, expenses, and deductions. (1) The PHA must conduct a reexamination of family income and composition at least annually. (2) Except as provided in paragraph (a)(3) of this section, the PHA must obtain and document in the tenant file third-party verification of the following factors, or must document in the tenant file why third-party verification was not available: a. Reported family annual income; b. The value of assets; c. Expenses related to deductions from annual income; and d. Other factors that affect the determination of adjusted income (24 CFR 982.516) CONDITION As a result of our audit procedures, we identified the following: ? One instance of insufficient or missing verification of income, expenses or deductions. ? One instance of an improperly executed release of information form. CAUSE The Authority had not fully implemented corrective actions initiated after prior year findings. EFFECT By not properly verification income and expenses, the Authority may not properly calculated income and thereby tenant rent and HAP expense. QUESTIONED COSTS None identified. CONTEXT We selected a sample of 20 vouchers from a population of 56. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2019-003. RECOMMENDATION We recommend that the Authority continue with the corrective action undertaken during the fiscal year, which involved subcontracting the administration of the Housing Choice Voucher Program to the Dedham Housing Authority. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2020-001 ? Eligibility: Rent Calculation Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Voucher Cluster CRITERIA The PHA is responsible for reexamination and verification of income, expenses, and deductions. (1) The PHA must conduct a reexamination of family income and composition at least annually. (2) Except as provided in paragraph (a)(3) of this section, the PHA must obtain and document in the tenant file third-party verification of the following factors, or must document in the tenant file why third-party verification was not available: a. Reported family annual income; b. The value of assets; c. Expenses related to deductions from annual income; and d. Other factors that affect the determination of adjusted income (24 CFR 982.516) CONDITION As a result of our audit procedures, we identified the following: ? One instance of insufficient or missing verification of income, expenses or deductions. ? One instance of an improperly executed release of information form. CAUSE The Authority had not fully implemented corrective actions initiated after prior year findings. EFFECT By not properly verification income and expenses, the Authority may not properly calculated income and thereby tenant rent and HAP expense. QUESTIONED COSTS None identified. CONTEXT We selected a sample of 20 vouchers from a population of 56. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2019-003. RECOMMENDATION We recommend that the Authority continue with the corrective action undertaken during the fiscal year, which involved subcontracting the administration of the Housing Choice Voucher Program to the Dedham Housing Authority. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
CORRECTIVE ACTION PLAN 2020-001 ? Eligibility: Rent Calculation Auditee?s Response and Planned Corrective Action Findings: One incomplete Form 9886 and one missing Enterprise Income Verification (EIV) Both these findings were noted by the Dedham Housing Authority during its comprehensive review of all files. Dedham used its checklist in reviewing each file. The subsequent Form 9886 for the specific tenant was signed on 12/28/2020. Thus, it was identified and resolved prior to the audit. However, this resolution date is outside the audit period and accordingly remains a finding for the audit period. The missing EIV was similarly noted during the review of all files and an EIV for the specific tenant was completed on 12/7/2020. Similarly, this resolution date is outside the audit period and accordingly remains a finding for the audit period. Accordingly, both findings were noted prior to the actual audit and resolved. The Dedham Housing Authority manages and administers the Program for the Billerica Housing Authority. Their experience, expertise and program knowledge will insure compliance and program integrity. Planned Implementation Date of Corrective Action: December 2020 Person Responsible for Corrective Action: Dedham Housing Authority
2019-003
FAC accepted this audit on March 30, 2020 — management decision was due September 30, 2020.
2019-002 ? Internal Controls over Compliance Material Weakness U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The A-102 Common Rule and OMB Circular A-110 require that non-Federal entities receiving Federal awards (e.g., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. (OMB Compliance Supplement, Part 6) The HA must maintain complete and accurate books of account and records for a program. The books and records must be in accordance with HUD requirements, and must permit a speedy and effective audit. (Consolidated Annual Contributions Contract) CONDITION The Authority has not maintained an effective control environment over its federal programs. We identified the following deficiencies in internal controls: ? The Authority has operated its Housing Choice Voucher Program without a complete and current Section 8 Administrative Plan. ? The Authority has not taken timely or appropriate corrective action for prior year audit findings from fiscal years 2017 and 2018. ? The Authority has not provided Housing Choice Voucher Program training to key staff with the responsibility of administering the program. CAUSE Prior to December of 2019, when a consultant was hired to address deficiencies in the Housing Choice Voucher Program, the Authority had not committed the resources necessary to make internal control improvements and address deficiencies identified in prior audits. EFFECT For the year ended June 30, 2019, the Authority cannot reasonably ensure compliance with the requirements of the Housing Choice Voucher Program. QUESTIONED COSTS None identified. CONTEXT Internal controls over compliance encompass the entirety of the Authority?s operation of the Housing Choice Voucher Program. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority continue with the corrective actions initiated in December of 2019. Furthermore, the Authority should consider a permanent arrangement for the Housing Choice Voucher Program to be administered by another agency, similar to how other local housing authorities have chosen to outsource the administration of the program. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-002 ? Internal Controls over Compliance Material Weakness U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The A-102 Common Rule and OMB Circular A-110 require that non-Federal entities receiving Federal awards (e.g., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. (OMB Compliance Supplement, Part 6) The HA must maintain complete and accurate books of account and records for a program. The books and records must be in accordance with HUD requirements, and must permit a speedy and effective audit. (Consolidated Annual Contributions Contract) CONDITION The Authority has not maintained an effective control environment over its federal programs. We identified the following deficiencies in internal controls: ? The Authority has operated its Housing Choice Voucher Program without a complete and current Section 8 Administrative Plan. ? The Authority has not taken timely or appropriate corrective action for prior year audit findings from fiscal years 2017 and 2018. ? The Authority has not provided Housing Choice Voucher Program training to key staff with the responsibility of administering the program. CAUSE Prior to December of 2019, when a consultant was hired to address deficiencies in the Housing Choice Voucher Program, the Authority had not committed the resources necessary to make internal control improvements and address deficiencies identified in prior audits. EFFECT For the year ended June 30, 2019, the Authority cannot reasonably ensure compliance with the requirements of the Housing Choice Voucher Program. QUESTIONED COSTS None identified. CONTEXT Internal controls over compliance encompass the entirety of the Authority?s operation of the Housing Choice Voucher Program. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority continue with the corrective actions initiated in December of 2019. Furthermore, the Authority should consider a permanent arrangement for the Housing Choice Voucher Program to be administered by another agency, similar to how other local housing authorities have chosen to outsource the administration of the program. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Effective 2/1/2020, the process for making mobile Housing Choice Voucher payments has been segregated. The Section 8 Administrator is responsible for forwarding an excel spreadsheet identifying the monthly HAP changes to the bookkeeper. The bookkeeper will generate the payments and ensure check payments match the identified changes. The Section 8 Administrative Plan was updated and approved by the Board of Commissioners on 11/7/2019 and submitted to HUD on 11/12/2019. The Billerica Housing Authority determined that providing training to existing staff to administer the HCV program was not a viable option. An internal decision was made to create a new position to administer the program. The BHA advertised the position in NAHRO?s Classified employment advertisements and hired an experienced part-time Section 8 Administrator to administer the mobile HCV program in December 2019. Beginning with February 2020 recertifications, the BHA has implemented procedures to ensure that proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. Included in these procedures, the BHA initiates the annual recertification process 90?120 days in advance of the recertification effective date. The participant recertification package has been updated to facilitate the collection of complete income, expenses, and deduction information which will ensure proper calculation of annual income, adjusted income, and thus rent. The BHA now requests that owners complete a 52517 - Request for Tenancy Approval form - to ensure the accuracy of contract rent, utility type and utility payment responsibility information. Unit type discrepancies between the RFTA and inspection reported types are resolved to ensure verification of the property utility allowance application. Utility allowance and payment standard schedules are maintained in the participant file. Third party verification of income, assets, expenses and related deductions from annual income is collected and maintained in the participant file. A comprehensive review of the participant file is being conducted at annual recertification. The review includes organizing the file into a multi part filing system. The use of the multi part filing system ensures file organization and verifies the file contains rent reasonableness, an executed HAP contract, an executed lease, Declaration of Status 214 forms, identity verification data, inspection reports, recertification verification, and other permanent records which can be rolled forward. A checklist is included with every file to ensure completeness. Participants and owners are being requested to submit missing data as part of the recertification process. The BHA contracts with McCright & Associates to conduct annual inspections, QC inspections, and Rent Reasonableness determinations. McCright & Associates staff is highly trained in HQS requirements. All inspection checklists, notices of abatement, notices of termination of HAP contract and all other written documentation of correspondence with the owner or tenant in regard to the HQS inspection are maintained in the tenant file. Weekly and monthly reports provided by McCright & Associates assist the BHA in ensuring HQS Enforcement. Abatement need is reviewed prior to the monthly processing of HAP payment to ensure compliance. An annual HQS inspection is being conducted for all assisted units that have not been conducted and the inspection date listed on the 50058 is verified at annual recertification and as inspections are conducted by McCright & Associates. A monthly inspection report is being submitted to McCright to ensure all inspections are conducted timely. A rent reasonableness determination is being requested from McCright & Associates for all assisted units that are missing the determination, requesting an increase, initially leasing a unit, or if there is a 10% decrease in the published FMR. The BHA recognizes that it has been a slow process to implement actions to address the previously noted conditions. However, the above Corrective Action Plan has been implemented and is addressing the deficiencies. Since this recent Audit was limited to the audit period ended June 30, 2019, the timing of implemented and meaningful corrective actions taken in late 2019 are not directly reflected in the results of this report. Nonetheless, the BHA is committed to continuing the resolution of deficiencies with an end result of having a stronger compliant program. Planned Implementation Date of Corrective Action: Already Implemented Person Responsible for Corrective Action: Anne-Marie Moglia (Section 8 Administrator) and Robert M. Correnti (Executive Director)
2019-003 ? Eligibility Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The PHA is responsible for reexamination and verification of income, expenses, and deductions. (1) The PHA must conduct a reexamination of family income and composition at least annually. (2) Except as provided in paragraph (a)(3) of this section, the PHA must obtain and document in the tenant file third-party verification of the following factors, or must document in the tenant file why third-party verification was not available: a. Reported family annual income; b. The value of assets; c. Expenses related to deductions from annual income; and d. Other factors that affect the determination of adjusted income (24 CFR 982.516) CONDITION As a result of our audit procedures, we identified the following: ? 5 instances of insufficient or missing verifications of income, expenses or deductions. ? 10 instances where the separately stated Utility Allowance was not consistent with the Utility Allowance obligations covered under the HAP contract either because the HAP contract was not present, incorrectly completed or the information within was contradictory. CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority did not implement procedures that ensured proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. 2019-003 ? Eligibility (Continued) QUESTIONED COSTS Due to substantially all vouchers lacking a correct rent calculation, lacking an adequate rent reasonableness determination (see Finding 2019-004), or lacking an adequate HAP contract (see Finding 2019-005), we have identified likely questioned costs of the $751,910. This represents the total of housing assistance payments for the year ended June 30, 2019, less known questioned costs identified in Finding 2019-007. CONTEXT We selected a sample of 15 vouchers from a population of 54. This was not a statistically valid sample. REPEAT FINDING Repeat of Finding 2018-002 from the prior year. RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-003 ? Eligibility Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The PHA is responsible for reexamination and verification of income, expenses, and deductions. (1) The PHA must conduct a reexamination of family income and composition at least annually. (2) Except as provided in paragraph (a)(3) of this section, the PHA must obtain and document in the tenant file third-party verification of the following factors, or must document in the tenant file why third-party verification was not available: a. Reported family annual income; b. The value of assets; c. Expenses related to deductions from annual income; and d. Other factors that affect the determination of adjusted income (24 CFR 982.516) CONDITION As a result of our audit procedures, we identified the following: ? 5 instances of insufficient or missing verifications of income, expenses or deductions. ? 10 instances where the separately stated Utility Allowance was not consistent with the Utility Allowance obligations covered under the HAP contract either because the HAP contract was not present, incorrectly completed or the information within was contradictory. CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority did not implement procedures that ensured proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. 2019-003 ? Eligibility (Continued) QUESTIONED COSTS Due to substantially all vouchers lacking a correct rent calculation, lacking an adequate rent reasonableness determination (see Finding 2019-004), or lacking an adequate HAP contract (see Finding 2019-005), we have identified likely questioned costs of the $751,910. This represents the total of housing assistance payments for the year ended June 30, 2019, less known questioned costs identified in Finding 2019-007. CONTEXT We selected a sample of 15 vouchers from a population of 54. This was not a statistically valid sample. REPEAT FINDING Repeat of Finding 2018-002 from the prior year. RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Effective 2/1/2020, the process for making mobile Housing Choice Voucher payments has been segregated. The Section 8 Administrator is responsible for forwarding an excel spreadsheet identifying the monthly HAP changes to the bookkeeper. The bookkeeper will generate the payments and ensure check payments match the identified changes. The Section 8 Administrative Plan was updated and approved by the Board of Commissioners on 11/7/2019 and submitted to HUD on 11/12/2019. The Billerica Housing Authority determined that providing training to existing staff to administer the HCV program was not a viable option. An internal decision was made to create a new position to administer the program. The BHA advertised the position in NAHRO?s Classified employment advertisements and hired an experienced part-time Section 8 Administrator to administer the mobile HCV program in December 2019. Beginning with February 2020 recertifications, the BHA has implemented procedures to ensure that proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. Included in these procedures, the BHA initiates the annual recertification process 90?120 days in advance of the recertification effective date. The participant recertification package has been updated to facilitate the collection of complete income, expenses, and deduction information which will ensure proper calculation of annual income, adjusted income, and thus rent. The BHA now requests that owners complete a 52517 - Request for Tenancy Approval form - to ensure the accuracy of contract rent, utility type and utility payment responsibility information. Unit type discrepancies between the RFTA and inspection reported types are resolved to ensure verification of the property utility allowance application. Utility allowance and payment standard schedules are maintained in the participant file. Third party verification of income, assets, expenses and related deductions from annual income is collected and maintained in the participant file. A comprehensive review of the participant file is being conducted at annual recertification. The review includes organizing the file into a multi part filing system. The use of the multi part filing system ensures file organization and verifies the file contains rent reasonableness, an executed HAP contract, an executed lease, Declaration of Status 214 forms, identity verification data, inspection reports, recertification verification, and other permanent records which can be rolled forward. A checklist is included with every file to ensure completeness. Participants and owners are being requested to submit missing data as part of the recertification process. The BHA contracts with McCright & Associates to conduct annual inspections, QC inspections, and Rent Reasonableness determinations. McCright & Associates staff is highly trained in HQS requirements. All inspection checklists, notices of abatement, notices of termination of HAP contract and all other written documentation of correspondence with the owner or tenant in regard to the HQS inspection are maintained in the tenant file. Weekly and monthly reports provided by McCright & Associates assist the BHA in ensuring HQS Enforcement. Abatement need is reviewed prior to the monthly processing of HAP payment to ensure compliance. An annual HQS inspection is being conducted for all assisted units that have not been conducted and the inspection date listed on the 50058 is verified at annual recertification and as inspections are conducted by McCright & Associates. A monthly inspection report is being submitted to McCright to ensure all inspections are conducted timely. A rent reasonableness determination is being requested from McCright & Associates for all assisted units that are missing the determination, requesting an increase, initially leasing a unit, or if there is a 10% decrease in the published FMR. The BHA recognizes that it has been a slow process to implement actions to address the previously noted conditions. However, the above Corrective Action Plan has been implemented and is addressing the deficiencies. Since this recent Audit was limited to the audit period ended June 30, 2019, the timing of implemented and meaningful corrective actions taken in late 2019 are not directly reflected in the results of this report. Nonetheless, the BHA is committed to continuing the resolution of deficiencies with an end result of having a stronger compliant program. Planned Implementation Date of Corrective Action: Already Implemented Person Responsible for Corrective Action: Anne-Marie Moglia (Section 8 Administrator) and Robert M. Correnti (Executive Director)
2018-002
2019-004 ? Special Tests & Provisions: Rent Reasonableness Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The PHA may not approve a lease until the PHA determines that the initial rent to an owner is a reasonable rent. (2) The PHA must redetermine the reasonable rent: (i) Before any increase in the rent to an owner; (ii) If there is a 10 percent decrease in the published FMR in effect 60 days before the contract anniversary (for the unit size rented by the family) as compared with the FMR in effect 1 year before the contract anniversary. (iii) If directed by HUD. The PHA may also redetermine the reasonable rent at any other time. At all times during the assisted tenancy, the rent to owner may not exceed the reasonable rent as most recently determined or redetermined by the PHA. (24 CFR 982.507) CONDITION We identified 9 instances in which the Authority was required to perform an assessment to determine if the rent requested by the landlord is reasonable. In all nine, the Authority did not perform this rent reasonableness assessment. CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS See Finding 2019-003. 2019-004 ? Special Tests & Provisions: Rent Reasonableness (Continued) CONTEXT We selected a sample of 15 from a population of 54 voucher holders in the housing choice voucher program. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-004 ? Special Tests & Provisions: Rent Reasonableness Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The PHA may not approve a lease until the PHA determines that the initial rent to an owner is a reasonable rent. (2) The PHA must redetermine the reasonable rent: (i) Before any increase in the rent to an owner; (ii) If there is a 10 percent decrease in the published FMR in effect 60 days before the contract anniversary (for the unit size rented by the family) as compared with the FMR in effect 1 year before the contract anniversary. (iii) If directed by HUD. The PHA may also redetermine the reasonable rent at any other time. At all times during the assisted tenancy, the rent to owner may not exceed the reasonable rent as most recently determined or redetermined by the PHA. (24 CFR 982.507) CONDITION We identified 9 instances in which the Authority was required to perform an assessment to determine if the rent requested by the landlord is reasonable. In all nine, the Authority did not perform this rent reasonableness assessment. CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS See Finding 2019-003. 2019-004 ? Special Tests & Provisions: Rent Reasonableness (Continued) CONTEXT We selected a sample of 15 from a population of 54 voucher holders in the housing choice voucher program. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Effective 2/1/2020, the process for making mobile Housing Choice Voucher payments has been segregated. The Section 8 Administrator is responsible for forwarding an excel spreadsheet identifying the monthly HAP changes to the bookkeeper. The bookkeeper will generate the payments and ensure check payments match the identified changes. The Section 8 Administrative Plan was updated and approved by the Board of Commissioners on 11/7/2019 and submitted to HUD on 11/12/2019. The Billerica Housing Authority determined that providing training to existing staff to administer the HCV program was not a viable option. An internal decision was made to create a new position to administer the program. The BHA advertised the position in NAHRO?s Classified employment advertisements and hired an experienced part-time Section 8 Administrator to administer the mobile HCV program in December 2019. Beginning with February 2020 recertifications, the BHA has implemented procedures to ensure that proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. Included in these procedures, the BHA initiates the annual recertification process 90?120 days in advance of the recertification effective date. The participant recertification package has been updated to facilitate the collection of complete income, expenses, and deduction information which will ensure proper calculation of annual income, adjusted income, and thus rent. The BHA now requests that owners complete a 52517 - Request for Tenancy Approval form - to ensure the accuracy of contract rent, utility type and utility payment responsibility information. Unit type discrepancies between the RFTA and inspection reported types are resolved to ensure verification of the property utility allowance application. Utility allowance and payment standard schedules are maintained in the participant file. Third party verification of income, assets, expenses and related deductions from annual income is collected and maintained in the participant file. A comprehensive review of the participant file is being conducted at annual recertification. The review includes organizing the file into a multi part filing system. The use of the multi part filing system ensures file organization and verifies the file contains rent reasonableness, an executed HAP contract, an executed lease, Declaration of Status 214 forms, identity verification data, inspection reports, recertification verification, and other permanent records which can be rolled forward. A checklist is included with every file to ensure completeness. Participants and owners are being requested to submit missing data as part of the recertification process. The BHA contracts with McCright & Associates to conduct annual inspections, QC inspections, and Rent Reasonableness determinations. McCright & Associates staff is highly trained in HQS requirements. All inspection checklists, notices of abatement, notices of termination of HAP contract and all other written documentation of correspondence with the owner or tenant in regard to the HQS inspection are maintained in the tenant file. Weekly and monthly reports provided by McCright & Associates assist the BHA in ensuring HQS Enforcement. Abatement need is reviewed prior to the monthly processing of HAP payment to ensure compliance. An annual HQS inspection is being conducted for all assisted units that have not been conducted and the inspection date listed on the 50058 is verified at annual recertification and as inspections are conducted by McCright & Associates. A monthly inspection report is being submitted to McCright to ensure all inspections are conducted timely. A rent reasonableness determination is being requested from McCright & Associates for all assisted units that are missing the determination, requesting an increase, initially leasing a unit, or if there is a 10% decrease in the published FMR. The BHA recognizes that it has been a slow process to implement actions to address the previously noted conditions. However, the above Corrective Action Plan has been implemented and is addressing the deficiencies. Since this recent Audit was limited to the audit period ended June 30, 2019, the timing of implemented and meaningful corrective actions taken in late 2019 are not directly reflected in the results of this report. Nonetheless, the BHA is committed to continuing the resolution of deficiencies with an end result of having a stronger compliant program. Planned Implementation Date of Corrective Action: Already Implemented Person Responsible for Corrective Action: Anne-Marie Moglia (Section 8 Administrator) and Robert M. Correnti (Executive Director)
2019-005 ? Special Tests & Provisions: HAP Payment Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The HAP contract must be in the form required by HUD (form HUD-52641). The term of the HAP contract is the same as the term of the lease. The amount of the monthly housing assistance payment by the PHA to the owner is determined by the PHA in accordance with HUD regulations and other requirements. The amount of the housing assistance payment is subject to change during the HAP contract term. The monthly housing assistance payment by the PHA is credited toward the monthly rent to owner under the family's lease. The PHA must pay the housing assistance payment promptly when due to the owner in accordance with the HAP contract. (24 CFR 982.451) CONDITION We identified 14 instances in which the Authority was missing, or had retained incorrectly completed, HAP contracts. CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority cannot reasonably ensure that housing assistance payments are adequately supported. QUESTIONED COSTS See Finding 2019-003. CONTEXT We selected a sample of 15 from a population of 54 voucher holders in the housing choice voucher program. This was not a statistically valid sample. 2019-005 ? Special Tests & Provisions: HAP Payment (Continued) REPEAT FINDING Not a repeat finding. RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-005 ? Special Tests & Provisions: HAP Payment Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The HAP contract must be in the form required by HUD (form HUD-52641). The term of the HAP contract is the same as the term of the lease. The amount of the monthly housing assistance payment by the PHA to the owner is determined by the PHA in accordance with HUD regulations and other requirements. The amount of the housing assistance payment is subject to change during the HAP contract term. The monthly housing assistance payment by the PHA is credited toward the monthly rent to owner under the family's lease. The PHA must pay the housing assistance payment promptly when due to the owner in accordance with the HAP contract. (24 CFR 982.451) CONDITION We identified 14 instances in which the Authority was missing, or had retained incorrectly completed, HAP contracts. CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority cannot reasonably ensure that housing assistance payments are adequately supported. QUESTIONED COSTS See Finding 2019-003. CONTEXT We selected a sample of 15 from a population of 54 voucher holders in the housing choice voucher program. This was not a statistically valid sample. 2019-005 ? Special Tests & Provisions: HAP Payment (Continued) REPEAT FINDING Not a repeat finding. RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Effective 2/1/2020, the process for making mobile Housing Choice Voucher payments has been segregated. The Section 8 Administrator is responsible for forwarding an excel spreadsheet identifying the monthly HAP changes to the bookkeeper. The bookkeeper will generate the payments and ensure check payments match the identified changes. The Section 8 Administrative Plan was updated and approved by the Board of Commissioners on 11/7/2019 and submitted to HUD on 11/12/2019. The Billerica Housing Authority determined that providing training to existing staff to administer the HCV program was not a viable option. An internal decision was made to create a new position to administer the program. The BHA advertised the position in NAHRO?s Classified employment advertisements and hired an experienced part-time Section 8 Administrator to administer the mobile HCV program in December 2019. Beginning with February 2020 recertifications, the BHA has implemented procedures to ensure that proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. Included in these procedures, the BHA initiates the annual recertification process 90?120 days in advance of the recertification effective date. The participant recertification package has been updated to facilitate the collection of complete income, expenses, and deduction information which will ensure proper calculation of annual income, adjusted income, and thus rent. The BHA now requests that owners complete a 52517 - Request for Tenancy Approval form - to ensure the accuracy of contract rent, utility type and utility payment responsibility information. Unit type discrepancies between the RFTA and inspection reported types are resolved to ensure verification of the property utility allowance application. Utility allowance and payment standard schedules are maintained in the participant file. Third party verification of income, assets, expenses and related deductions from annual income is collected and maintained in the participant file. A comprehensive review of the participant file is being conducted at annual recertification. The review includes organizing the file into a multi part filing system. The use of the multi part filing system ensures file organization and verifies the file contains rent reasonableness, an executed HAP contract, an executed lease, Declaration of Status 214 forms, identity verification data, inspection reports, recertification verification, and other permanent records which can be rolled forward. A checklist is included with every file to ensure completeness. Participants and owners are being requested to submit missing data as part of the recertification process. The BHA contracts with McCright & Associates to conduct annual inspections, QC inspections, and Rent Reasonableness determinations. McCright & Associates staff is highly trained in HQS requirements. All inspection checklists, notices of abatement, notices of termination of HAP contract and all other written documentation of correspondence with the owner or tenant in regard to the HQS inspection are maintained in the tenant file. Weekly and monthly reports provided by McCright & Associates assist the BHA in ensuring HQS Enforcement. Abatement need is reviewed prior to the monthly processing of HAP payment to ensure compliance. An annual HQS inspection is being conducted for all assisted units that have not been conducted and the inspection date listed on the 50058 is verified at annual recertification and as inspections are conducted by McCright & Associates. A monthly inspection report is being submitted to McCright to ensure all inspections are conducted timely. A rent reasonableness determination is being requested from McCright & Associates for all assisted units that are missing the determination, requesting an increase, initially leasing a unit, or if there is a 10% decrease in the published FMR. The BHA recognizes that it has been a slow process to implement actions to address the previously noted conditions. However, the above Corrective Action Plan has been implemented and is addressing the deficiencies. Since this recent Audit was limited to the audit period ended June 30, 2019, the timing of implemented and meaningful corrective actions taken in late 2019 are not directly reflected in the results of this report. Nonetheless, the BHA is committed to continuing the resolution of deficiencies with an end result of having a stronger compliant program. Planned Implementation Date of Corrective Action: Already Implemented Person Responsible for Corrective Action: Anne-Marie Moglia (Section 8 Administrator) and Robert M. Correnti (Executive Director)
2019-006 ? Reporting- Performance Reporting Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA 24 CFR 982.105; 24 CFR Part 985 requires and sets criteria for annual Section Eight Management Asset Program (SEMAP) assessment including that the supporting documentation used to conduct the assessment be maintained and should leave a clear audit trail. CONDITION For the following indicators in the assessment, the Authority was not able to provide the supporting documentation used to conduct the SEMAP assessment: (i) Indicator 1 ? Selection from the Waiting List (ii) Indicator 2 - Reasonable Rent (iii) Indicator 3 ? Adjusted Income CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority incorrectly conducted the SEMAP certification and potentially incorrectly reported the performance rating. QUESTIONED COSTS None identified. CONTEXT The Authority conducts the SEMAP assessment on an annual basis. REPEAT FINDING Not a repeat finding. 2019-006 ? Reporting- Performance Reporting (Continued) RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-006 ? Reporting- Performance Reporting Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA 24 CFR 982.105; 24 CFR Part 985 requires and sets criteria for annual Section Eight Management Asset Program (SEMAP) assessment including that the supporting documentation used to conduct the assessment be maintained and should leave a clear audit trail. CONDITION For the following indicators in the assessment, the Authority was not able to provide the supporting documentation used to conduct the SEMAP assessment: (i) Indicator 1 ? Selection from the Waiting List (ii) Indicator 2 - Reasonable Rent (iii) Indicator 3 ? Adjusted Income CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority incorrectly conducted the SEMAP certification and potentially incorrectly reported the performance rating. QUESTIONED COSTS None identified. CONTEXT The Authority conducts the SEMAP assessment on an annual basis. REPEAT FINDING Not a repeat finding. 2019-006 ? Reporting- Performance Reporting (Continued) RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Effective 2/1/2020, the process for making mobile Housing Choice Voucher payments has been segregated. The Section 8 Administrator is responsible for forwarding an excel spreadsheet identifying the monthly HAP changes to the bookkeeper. The bookkeeper will generate the payments and ensure check payments match the identified changes. The Section 8 Administrative Plan was updated and approved by the Board of Commissioners on 11/7/2019 and submitted to HUD on 11/12/2019. The Billerica Housing Authority determined that providing training to existing staff to administer the HCV program was not a viable option. An internal decision was made to create a new position to administer the program. The BHA advertised the position in NAHRO?s Classified employment advertisements and hired an experienced part-time Section 8 Administrator to administer the mobile HCV program in December 2019. Beginning with February 2020 recertifications, the BHA has implemented procedures to ensure that proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. Included in these procedures, the BHA initiates the annual recertification process 90?120 days in advance of the recertification effective date. The participant recertification package has been updated to facilitate the collection of complete income, expenses, and deduction information which will ensure proper calculation of annual income, adjusted income, and thus rent. The BHA now requests that owners complete a 52517 - Request for Tenancy Approval form - to ensure the accuracy of contract rent, utility type and utility payment responsibility information. Unit type discrepancies between the RFTA and inspection reported types are resolved to ensure verification of the property utility allowance application. Utility allowance and payment standard schedules are maintained in the participant file. Third party verification of income, assets, expenses and related deductions from annual income is collected and maintained in the participant file. A comprehensive review of the participant file is being conducted at annual recertification. The review includes organizing the file into a multi part filing system. The use of the multi part filing system ensures file organization and verifies the file contains rent reasonableness, an executed HAP contract, an executed lease, Declaration of Status 214 forms, identity verification data, inspection reports, recertification verification, and other permanent records which can be rolled forward. A checklist is included with every file to ensure completeness. Participants and owners are being requested to submit missing data as part of the recertification process. The BHA contracts with McCright & Associates to conduct annual inspections, QC inspections, and Rent Reasonableness determinations. McCright & Associates staff is highly trained in HQS requirements. All inspection checklists, notices of abatement, notices of termination of HAP contract and all other written documentation of correspondence with the owner or tenant in regard to the HQS inspection are maintained in the tenant file. Weekly and monthly reports provided by McCright & Associates assist the BHA in ensuring HQS Enforcement. Abatement need is reviewed prior to the monthly processing of HAP payment to ensure compliance. An annual HQS inspection is being conducted for all assisted units that have not been conducted and the inspection date listed on the 50058 is verified at annual recertification and as inspections are conducted by McCright & Associates. A monthly inspection report is being submitted to McCright to ensure all inspections are conducted timely. A rent reasonableness determination is being requested from McCright & Associates for all assisted units that are missing the determination, requesting an increase, initially leasing a unit, or if there is a 10% decrease in the published FMR. The BHA recognizes that it has been a slow process to implement actions to address the previously noted conditions. However, the above Corrective Action Plan has been implemented and is addressing the deficiencies. Since this recent Audit was limited to the audit period ended June 30, 2019, the timing of implemented and meaningful corrective actions taken in late 2019 are not directly reflected in the results of this report. Nonetheless, the BHA is committed to continuing the resolution of deficiencies with an end result of having a stronger compliant program. Planned Implementation Date of Corrective Action: Already Implemented Person Responsible for Corrective Action: Anne-Marie Moglia (Section 8 Administrator) and Robert M. Correnti (Executive Director)
2019-007 ? Special Tests & Provisions: Selection from the Waiting List Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. "Selection" from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). CONDITION We identified the following conditions during our audit: ? The Authority improperly issued a voucher in June of 2019 to an individual that was not on the waiting list. ? Despite having available vouchers and spendable budget authority under the Annual Contributions Contract, the Authority did not make any selections from the waiting list during the fiscal year. CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority is potentially making ineligible housing assistance payments and is not maximizing its ability to provide affordable housing. QUESTIONED COSTS Known questioned costs - $1,227. 2019-007 ? Special Tests & Provisions: Selection from the Waiting List (Continued) CONTEXT The Authority issued one voucher during the fiscal year. REPEAT FINDING Not a repeat finding. RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-007 ? Special Tests & Provisions: Selection from the Waiting List Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871 ? Housing Choice Voucher Program CRITERIA The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. "Selection" from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). CONDITION We identified the following conditions during our audit: ? The Authority improperly issued a voucher in June of 2019 to an individual that was not on the waiting list. ? Despite having available vouchers and spendable budget authority under the Annual Contributions Contract, the Authority did not make any selections from the waiting list during the fiscal year. CAUSE See conditions present in finding 2019-002 ? Internal Controls over Compliance. EFFECT The Authority is potentially making ineligible housing assistance payments and is not maximizing its ability to provide affordable housing. QUESTIONED COSTS Known questioned costs - $1,227. 2019-007 ? Special Tests & Provisions: Selection from the Waiting List (Continued) CONTEXT The Authority issued one voucher during the fiscal year. REPEAT FINDING Not a repeat finding. RECOMMENDATION See Finding 2019-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Effective 2/1/2020, the process for making mobile Housing Choice Voucher payments has been segregated. The Section 8 Administrator is responsible for forwarding an excel spreadsheet identifying the monthly HAP changes to the bookkeeper. The bookkeeper will generate the payments and ensure check payments match the identified changes. The Section 8 Administrative Plan was updated and approved by the Board of Commissioners on 11/7/2019 and submitted to HUD on 11/12/2019. The Billerica Housing Authority determined that providing training to existing staff to administer the HCV program was not a viable option. An internal decision was made to create a new position to administer the program. The BHA advertised the position in NAHRO?s Classified employment advertisements and hired an experienced part-time Section 8 Administrator to administer the mobile HCV program in December 2019. Beginning with February 2020 recertifications, the BHA has implemented procedures to ensure that proper verification and calculation of income, expenses, and deductions are used in calculating annual income, adjusted income, and thereby rent. Included in these procedures, the BHA initiates the annual recertification process 90?120 days in advance of the recertification effective date. The participant recertification package has been updated to facilitate the collection of complete income, expenses, and deduction information which will ensure proper calculation of annual income, adjusted income, and thus rent. The BHA now requests that owners complete a 52517 - Request for Tenancy Approval form - to ensure the accuracy of contract rent, utility type and utility payment responsibility information. Unit type discrepancies between the RFTA and inspection reported types are resolved to ensure verification of the property utility allowance application. Utility allowance and payment standard schedules are maintained in the participant file. Third party verification of income, assets, expenses and related deductions from annual income is collected and maintained in the participant file. A comprehensive review of the participant file is being conducted at annual recertification. The review includes organizing the file into a multi part filing system. The use of the multi part filing system ensures file organization and verifies the file contains rent reasonableness, an executed HAP contract, an executed lease, Declaration of Status 214 forms, identity verification data, inspection reports, recertification verification, and other permanent records which can be rolled forward. A checklist is included with every file to ensure completeness. Participants and owners are being requested to submit missing data as part of the recertification process. The BHA contracts with McCright & Associates to conduct annual inspections, QC inspections, and Rent Reasonableness determinations. McCright & Associates staff is highly trained in HQS requirements. All inspection checklists, notices of abatement, notices of termination of HAP contract and all other written documentation of correspondence with the owner or tenant in regard to the HQS inspection are maintained in the tenant file. Weekly and monthly reports provided by McCright & Associates assist the BHA in ensuring HQS Enforcement. Abatement need is reviewed prior to the monthly processing of HAP payment to ensure compliance. An annual HQS inspection is being conducted for all assisted units that have not been conducted and the inspection date listed on the 50058 is verified at annual recertification and as inspections are conducted by McCright & Associates. A monthly inspection report is being submitted to McCright to ensure all inspections are conducted timely. A rent reasonableness determination is being requested from McCright & Associates for all assisted units that are missing the determination, requesting an increase, initially leasing a unit, or if there is a 10% decrease in the published FMR. The BHA recognizes that it has been a slow process to implement actions to address the previously noted conditions. However, the above Corrective Action Plan has been implemented and is addressing the deficiencies. Since this recent Audit was limited to the audit period ended June 30, 2019, the timing of implemented and meaningful corrective actions taken in late 2019 are not directly reflected in the results of this report. Nonetheless, the BHA is committed to continuing the resolution of deficiencies with an end result of having a stronger compliant program. Planned Implementation Date of Corrective Action: Already Implemented Person Responsible for Corrective Action: Anne-Marie Moglia (Section 8 Administrator) and Robert M. Correnti (Executive Director)
FAC accepted this audit on March 14, 2019 — management decision was due September 14, 2019.
GSA_MIGRATION
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2017-005
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2017-002
FAC accepted this audit on March 25, 2018 — management decision was due September 25, 2018.
GSA_MIGRATION
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GSA_MIGRATION
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GSA_MIGRATION
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