EIN: 046003708
UEI: NGFXCE3QD1E8
Audited by: CBIZ CPAS P.C.
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. 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 September 30, 2026 (31 days from today).
What is a management decision? →CRITERIA Any contract not exceeding $20,000 for construction or public improvements and $25,000 for goods or services may be made in accordance with the small purchase procedures. Contract requirements shall not be artificially divided so as to constitute a small purchase. When the value of the goods or services to be procured is greater than $3,000 but not greater than $20,000 for construction or public improvements and $25,000 for goods or services, the requisitioner must obtain three (3) or more quotations orally, by telephone, fax, in email or writing from qualified offerors by sending them a written solicitation for goods or services. An independent cost estimate (ICE) must also be performed by the requestor. (Pittsfield Housing Authority Procurement Policy) CONDITION We examined a sample of 4 vendors used for goods and services during fiscal year 2025 and identified 4 instances where the Authority did not follow their procurement policy or did not retain sufficient supporting documentation. CAUSE The Authority’s internal control over procurement was not effective at identifying the need for competitive procurement. EFFECT The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. QUESTIONED COSTS Estimated questioned costs of $674,449 representing the total payments to 4 vendors. CONTEXT We selected a sample of 4 vendors from a population of 33 vendors paid in excess of the micropurchase threshold. This was not a statistically valid sample. REPEAT FINDING See finding 2024-002. RECOMMENDATION We recommend that the Authority improve its monitoring of contracts and periodically assess the procurement implications of cumulative payments to frequently used vendors. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴CRITERIA Any contract not exceeding $20,000 for construction or public improvements and $25,000 for goods or services may be made in accordance with the small purchase procedures. Contract requirements shall not be artificially divided so as to constitute a small purchase. When the value of the goods or services to be procured is greater than $3,000 but not greater than $20,000 for construction or public improvements and $25,000 for goods or services, the requisitioner must obtain three (3) or more quotations orally, by telephone, fax, in email or writing from qualified offerors by sending them a written solicitation for goods or services. An independent cost estimate (ICE) must also be performed by the requestor. (Pittsfield Housing Authority Procurement Policy) CONDITION We examined a sample of 4 vendors used for goods and services during fiscal year 2025 and identified 4 instances where the Authority did not follow their procurement policy or did not retain sufficient supporting documentation. CAUSE The Authority’s internal control over procurement was not effective at identifying the need for competitive procurement. EFFECT The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. QUESTIONED COSTS Estimated questioned costs of $674,449 representing the total payments to 4 vendors. CONTEXT We selected a sample of 4 vendors from a population of 33 vendors paid in excess of the micropurchase threshold. This was not a statistically valid sample. REPEAT FINDING See finding 2024-002. RECOMMENDATION We recommend that the Authority improve its monitoring of contracts and periodically assess the procurement implications of cumulative payments to frequently used vendors. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
The Pittsfield Housing Authority received a designation of High Performer by the HUD Real Estate Assessment Center (REAC) for the fiscal year ending 6/30/25. Pittsfield Housing Authority overall SEMAP score for the fiscal year ended 6/30/24 is 91%. Executive Director Tina Danzy of the Pittsfield Housing Authority can address the Corrective Action Plan ending 6/30/25. FY ’25 included staff changes and reorganization of job descriptions. Director of Maintenance Patrick Pettit ended his employment at PHA May 2025, and his role of MOD coordinator has been assigned to Gwendolyn Cariddi who is currently receiving training for the position.
2024-002
FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
2024-001 –ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.850 – Public and Indian Housing CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 960.259). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 960.253, 960.255, 960.259). CONDITION As a result of our procedures, we identified the following exceptions in our testing: Fourteen (14) instances of income, asset or medical miscalculations or insufficient verification Twelve (12) instances of untimely reexamination CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted CONTEXT We selected a sample of 40 from a population of 153. This was not a statistically valid sample. REPEAT FINDING See finding 2023-003. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained.
Show full finding ▾Hide full finding ▴2024-001 –ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.850 – Public and Indian Housing CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 960.259). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 960.253, 960.255, 960.259). CONDITION As a result of our procedures, we identified the following exceptions in our testing: Fourteen (14) instances of income, asset or medical miscalculations or insufficient verification Twelve (12) instances of untimely reexamination CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted CONTEXT We selected a sample of 40 from a population of 153. This was not a statistically valid sample. REPEAT FINDING See finding 2023-003. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained.
2024-001 - Eligibility Rent Calculation Material Weakness/Material Noncompliance The Authority has made a corrective action and Section 8 has implemented a checklist to accompany the tenant file to ensure all required documentation is obtained. Other HUD properties, staff has been trained and certified in rent calculations and redetermination. There is on-going oversight by the Authority federal public housing manager and the federal public housing specialist. Planned Completion Date of Corrective Actions: June 30, 2025 Persons Responsible for Corrective Actions; Tina Danzy, Executive Director Tracy Pero, HCV/PIH Compliance
2023-003
2024-002 –PROCUREMENT AND SUSPENSION AND DEBARMENT Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.850 – Public and Indian Housing CRITERIA Any contract not exceeding $20,000 for construction or public improvements and $25,000 for goods or services may be made in accordance with the small purchase procedures. Contract requirements shall not be artificially divided so as to constitute a small purchase. For small purchases over $2,000, but not greater than $20,000 for construction or public improvements and $25,000 for goods or services no less than three offerors shall be solicited to submit price quotations. (Pittsfield Housing Authority Procurement Policy) CONDITION We examined a sample of 4 vendors used for goods and services during fiscal year 2024 and identified 3 instances where the Authority did not follow their procurement policy or did not retain sufficient supporting documentation. CAUSE The Authority’s internal control over procurement was not effective at identifying the need for competitive procurement. EFFECT The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. QUESTIONED COSTS Estimated questioned costs of $464,450 representing the total payments to 3 vendors. CONTEXT We selected a sample of 4 from a population of 35 vendors paid in excess of the micro-purchase threshold. This was not a statistically valid sample. REPEAT FINDING See finding 2023-004. RECOMMENDATION We recommend that the Authority improve its monitoring of contracts and periodically assess the procurement implications of cumulative payments to frequently used vendors. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-002 –PROCUREMENT AND SUSPENSION AND DEBARMENT Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.850 – Public and Indian Housing CRITERIA Any contract not exceeding $20,000 for construction or public improvements and $25,000 for goods or services may be made in accordance with the small purchase procedures. Contract requirements shall not be artificially divided so as to constitute a small purchase. For small purchases over $2,000, but not greater than $20,000 for construction or public improvements and $25,000 for goods or services no less than three offerors shall be solicited to submit price quotations. (Pittsfield Housing Authority Procurement Policy) CONDITION We examined a sample of 4 vendors used for goods and services during fiscal year 2024 and identified 3 instances where the Authority did not follow their procurement policy or did not retain sufficient supporting documentation. CAUSE The Authority’s internal control over procurement was not effective at identifying the need for competitive procurement. EFFECT The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. QUESTIONED COSTS Estimated questioned costs of $464,450 representing the total payments to 3 vendors. CONTEXT We selected a sample of 4 from a population of 35 vendors paid in excess of the micro-purchase threshold. This was not a statistically valid sample. REPEAT FINDING See finding 2023-004. RECOMMENDATION We recommend that the Authority improve its monitoring of contracts and periodically assess the procurement implications of cumulative payments to frequently used vendors. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2024-002 Procurement and Suspension and Debarment Material Weakness/Material Noncompliance The Authority’s Board of Commissioners approved an updated Procurement Policy in October 2024. The procedures are now in place and being followed to ensure compliance with: contract registers, procurement approval procedures, and monitoring of vendor payments. The Authority has two MCPPO certified procurement officers, The Executive Director Tina Danzy has been approved by the Board of Commissioners to be the Chief Procurement Officer of the Authority, additionally Patrick Pettit is also certified as a procurement officer. Planned Completion Date of Corrective Actions: June 30, 2025 Persons Responsible for Corrective Actions; Tina Danzy, Executive Director Tracy Pero, HCV/PIH Compliance
2023-004
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
2023-001 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871 – Housing Voucher Cluster CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 982.516). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 982.201, 982.515, 982.516). CONDITION As a result of our procedures, we identified five instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent and the housing assistance payment was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 40 from a population of 580. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2022-001. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained.
Show full finding ▾Hide full finding ▴2023-001 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871 – Housing Voucher Cluster CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 982.516). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 982.201, 982.515, 982.516). CONDITION As a result of our procedures, we identified five instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent and the housing assistance payment was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 40 from a population of 580. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2022-001. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained.
The finding of missing income verifications for eligibility and recertification rent calculations is being addressed as part of a holistic review under the Recovery Agreement of Section 8 program compliance. Following an internal SEMAP QC review in July 2023, staff have been retrained and certification/recertification checklists have been created. Initial and annual recertifications are currently being conducted in accordance with the applicable HUD regulations and guidance and will be internally reviewed during a July 2024 SEMAP QC review .
2022-001
2023-002 – SPECIAL TESTS AND PROVISIONS: RENT REASONABLENESS Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871 – Housing Voucher Cluster 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 The Authority did not perform rent reasonableness assessments. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS Questioned Costs - $4,337,214. CONTEXT We selected a sample of 40 from a population of 580. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2022-002. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained.
Show full finding ▾Hide full finding ▴2023-002 – SPECIAL TESTS AND PROVISIONS: RENT REASONABLENESS Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871 – Housing Voucher Cluster 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 The Authority did not perform rent reasonableness assessments. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS Questioned Costs - $4,337,214. CONTEXT We selected a sample of 40 from a population of 580. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2022-002. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained.
Effective 3/3/23, PHA switched from manual calculations of rent reasonableness to a web-based Rental Reasonableness software designed to meet HUD standards. PHA began conducting reasonableness determinations utilizing the Rent Reasonableness software, beginning March 2023. Rent reasonableness determinations are now being made for all participants prior to initial HAP contract execution and in conjunction with any requested rent increases. Continuing compliance will be internally reviewed during a July 2024 SEMAP QC review.
2022-002
2023-003 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.850 – Public and Indian Housing CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 960.259). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 960.253, 960.255, 960.259). CONDITION As a result of our procedures, we identified the following exceptions in our testing: Twenty-seven (27) instances of income, asset or medical miscalculations or insufficient verification Ten (10) instances of untimely reexaminations CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 40 from a population of 153. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2022-003. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained.
Show full finding ▾Hide full finding ▴2023-003 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.850 – Public and Indian Housing CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 960.259). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 960.253, 960.255, 960.259). CONDITION As a result of our procedures, we identified the following exceptions in our testing: Twenty-seven (27) instances of income, asset or medical miscalculations or insufficient verification Ten (10) instances of untimely reexaminations CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 40 from a population of 153. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2022-003. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained.
At the beginning of FY2024, under the terms of PHA's Recovery Agreement with HUD, PHA's consultants conducted PIH internal QCs and staffing assessments. As a result of those findings, PHA has reorganized and increased the PHA staff, with a new Public Housing Manager. Staff are being fully trained regarding eligibility determinations and rent calculations, checklists are being developed and regular internal QCs performed, with an objective of full compliance by the end of calendar year 2024.
2022-003
2023-004 – PROCUREMENT AND SUSPENSION AND DEBARMENT Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.850 – Public and Indian Housing CRITERIA Any contract not exceeding $20,000 for construction or public improvements and $25,000 for goods or services may be made in accordance with the small purchase procedures. Contract requirements shall not be artificially divided so as to constitute a small purchase. For small purchases over $2,000, but not greater than $20,000 for construction or public improvements and $25,000 for goods or services no less than three offerors shall be solicited to submit price quotations. (Pittsfield Housing Authority Procurement Policy) CONDITION We examined a sample of 5 vendors used for goods and services during fiscal year 2023 and identified 5 instances where the Authority did not follow their procurement policy or did not retain sufficient supporting documentation. 2023-004 – PROCUREMENT AND SUSPENSION AND DEBARMENT (CONTINUED) CAUSE The Authority’s internal control over procurement was not effective at identifying the need for competitive procurement in instances where frequently recurring transactions resulted in aggregate purchase in excess of competitive procurement thresholds. EFFECT The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. QUESTIONED COSTS Estimated questioned costs of $230,551 representing the total payments to these 5 vendors. CONTEXT We selected a sample of 5 from a population of approximately 50 vendors paid in excess of the micro-purchase threshold. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority improve its monitoring of contracts and periodically assess the procurement implications of cumulative payments to frequently used vendors.
Show full finding ▾Hide full finding ▴2023-004 – PROCUREMENT AND SUSPENSION AND DEBARMENT Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.850 – Public and Indian Housing CRITERIA Any contract not exceeding $20,000 for construction or public improvements and $25,000 for goods or services may be made in accordance with the small purchase procedures. Contract requirements shall not be artificially divided so as to constitute a small purchase. For small purchases over $2,000, but not greater than $20,000 for construction or public improvements and $25,000 for goods or services no less than three offerors shall be solicited to submit price quotations. (Pittsfield Housing Authority Procurement Policy) CONDITION We examined a sample of 5 vendors used for goods and services during fiscal year 2023 and identified 5 instances where the Authority did not follow their procurement policy or did not retain sufficient supporting documentation. 2023-004 – PROCUREMENT AND SUSPENSION AND DEBARMENT (CONTINUED) CAUSE The Authority’s internal control over procurement was not effective at identifying the need for competitive procurement in instances where frequently recurring transactions resulted in aggregate purchase in excess of competitive procurement thresholds. EFFECT The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. QUESTIONED COSTS Estimated questioned costs of $230,551 representing the total payments to these 5 vendors. CONTEXT We selected a sample of 5 from a population of approximately 50 vendors paid in excess of the micro-purchase threshold. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority improve its monitoring of contracts and periodically assess the procurement implications of cumulative payments to frequently used vendors.
Under the terms of its Recovery Agreement with HUD, Pittsfield HA is conducting a full review of its procurement policies, procedures, practices, documentation and internal controls. An updated Procurement Policy, compliant with both HUD and Massachusetts procurement requirements, has been drafted and is currently being reviewed by staff. Following Board adoption of the updated Procurement Policy, under the direction of Tina Danzy, the new Executive Director, steps will be taken to ensure that procurement activities, contracting, documentation and internal controls are in full compliance with HUD and EOHLC requirements by the end of calendar year 2024.
FAC accepted this audit on February 1, 2024 — management decision was due August 1, 2024.
2022-001 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 982.516). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 982.201, 982.515, 982.516). CONDITION As a result of our procedures, we identified five instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent and the housing assistance payment was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 25 vouchers from a population of 498. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2022-001 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 982.516). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 982.201, 982.515, 982.516). CONDITION As a result of our procedures, we identified five instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent and the housing assistance payment was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 25 vouchers from a population of 498. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-001 – Eligibility Rent Calculations –ALN#14.871 – Housing Voucher Cluster The finding of missing income verifications for eligibility and recertification rent calculations is being addressed as part of a holistic review under the Recovery Agreement of Section 8 program compliance, including an update to the Section 8 Administrative Plan, retraining for all Section 8 staff and implementation of initial and recertification checklists as well as regular QC audits. Planned Implementation Date of Corrective Action Reminders to Staff regarding appropriate verification of all income: Completed Updates to Section 8 Administrative Plan and ACOP: 12/31/23 Retraining of staff, checklists and QC audit procedures: 6/30/24 Person(s) Responsible for Corrective Actions: Paul Dettman, PHA Consultant Tracy Pero, Section 8 Staff Leased Housing Program Manager Senior Public Housing Manager
2022-002 – SPECIAL TESTS & PROVISIONS: RENT REASONABLENESS Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster 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 The Authority did not perform rent reasonableness assessments. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS Questioned costs - $3,874,736. CONTEXT We selected a sample of 25 vouchers from a population of 498. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2022-002 – SPECIAL TESTS & PROVISIONS: RENT REASONABLENESS Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster 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 The Authority did not perform rent reasonableness assessments. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT The Authority cannot ensure that HAP payments to landlords were reasonable. QUESTIONED COSTS Questioned costs - $3,874,736. CONTEXT We selected a sample of 25 vouchers from a population of 498. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-002–Rent Reasonableness Determination–ALN14.871– Housing Voucher Cluster Effective 3/3/23, PHA switched from manual calculations of rent reasonableness to a web-based Rental Reasonableness software designed to meet HUD standards. Rent reasonableness determinations are now being made for all participants prior to initial HAP contract execution and in conjunction with any requested rent increases. Planned Implementation Date of Corrective Action Reminders to Staff regarding appropriate verification of all income: Completed Updates to Section 8 Administrative Plan and ACOP: 12/31/23 Retraining of staff, checklists and QC audit procedures: 6/30/24 Person(s) Responsible for Corrective Actions Paul Dettman, PHA Consultant: Tracy Pero, Section 8 Staff Leased Housing Program Manager Senior Public Housing Manager
2022-003 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.850– Public and Indian Housing CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 960.259). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 960.253, 960.255, 960.259). CONDITION As a result of our procedures, we identified nine instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 16 tenants from a population of 152. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2022-003 – ELIGIBILITY: RENT CALCULATION Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.850– Public and Indian Housing CRITERIA For both family income examinations and reexamination, obtain and document in the family file third-party verification of (1) reported family annual income (2) the value of assets (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR Section 960.259). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third-party verification in accordance with 24 CFR Part 5 subpart F (24 CFR section 5.601 et seq.) (24CFR sections 960.253, 960.255, 960.259). CONDITION As a result of our procedures, we identified nine instances of missing income verification. CAUSE The Authority’s system of internal controls over the participant recertification process was not sufficient to meet the requirements established by HUD. EFFECT Redetermination of tenant’s rent was not performed in accordance with HUD regulations. As a result, tenants may have paid more or less in rent than they should have paid. QUESTIONED COSTS None noted. CONTEXT We selected a sample of 16 tenants from a population of 152. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement a recertification checklist to accompany the tenant file to ensure all required documentation is obtained. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-003 – Eligibility Rent Calculations – ALN#14.850 – Public & Indian Housing The finding of missing income verifications for eligibility and recertification rent calculations is being addressed as part of a holistic review under the Recovery Agreement of Federal Public Housing program compliance, including an update to the Admissions and Continued Occupancy Policy (ACOP), retraining for all Public Housing staff and implementation of initial and recertification checklists as well as regular QC audits. Planned Implementation Date of Corrective Action Reminders to Staff regarding appropriate verification of all income: Completed Updates to Section 8 Administrative Plan and ACOP: 12/31/23 Retraining of staff, checklists and QC audit procedures: 6/30/24 Person(s) Responsible for Corrective Actions: Paul Dettman, PHA Consultant Tracy Pero, Section 8 Staff Leased Housing Program Manager Senior Public Housing Manager
2022-004 – NONCOMPLIANCE: REPORTING Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster ALN #: 14.850– Public and Indian Housing CRITERIA Financial Reports (0MB No. 2535-0107) - Financial Assessment Sub- system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The FASSPH system is one of HUD's main monitoring and oversight systems for the HCV and PIH programs. CONDITION The Authority’s audited submission was not submitted by the deadline of March 31, 2023. CAUSE The Authority did not procure an auditor in a timely manner and was unable to submit the audited FDS by the deadline. EFFECT As a result of not submitting the FDS timely, HUD was limited in its ability to conduct monitoring and oversight of federal programs. QUESTIONED COSTS None noted. CONTEXT The Authority submits the audited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority improve the timing of the procurement process to ensure that the audited FDS is filed in a timely manner. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2022-004 – NONCOMPLIANCE: REPORTING Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development ALN #: 14.871– Housing Voucher Cluster ALN #: 14.850– Public and Indian Housing CRITERIA Financial Reports (0MB No. 2535-0107) - Financial Assessment Sub- system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The FASSPH system is one of HUD's main monitoring and oversight systems for the HCV and PIH programs. CONDITION The Authority’s audited submission was not submitted by the deadline of March 31, 2023. CAUSE The Authority did not procure an auditor in a timely manner and was unable to submit the audited FDS by the deadline. EFFECT As a result of not submitting the FDS timely, HUD was limited in its ability to conduct monitoring and oversight of federal programs. QUESTIONED COSTS None noted. CONTEXT The Authority submits the audited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority improve the timing of the procurement process to ensure that the audited FDS is filed in a timely manner. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.
2022-004 –Noncompliance Reporting – ALN#14.871 – Housing Voucher Cluster and ALN#14.850 – Public & Indian Housing The audit services procurement was a multiyear contract. The auditor for the 2023 audit is already in place and PHA will submit the 2023 audit timely. Planned Implementation Date of Corrective Action Reminders to Staff regarding appropriate verification of all income: Completed Updates to Section 8 Administrative Plan and ACOP: 12/31/23 Retraining of staff, checklists and QC audit procedures: 6/30/24 Person(s) Responsible for Corrective Actions: Paul Dettman, PHA Consultant Tracy Pero, Section 8 Staff Leased Housing Program Manager Senior Public Housing Manager
FAC accepted this audit on October 2, 2022 — management decision was due April 2, 2023.
FAC accepted this audit on September 29, 2021 — management decision was due March 29, 2022.
FAC accepted this audit on March 22, 2020 — management decision was due September 22, 2020.
FAC accepted this audit on March 10, 2019 — management decision was due September 10, 2019.
FAC accepted this audit on March 5, 2018 — management decision was due September 5, 2018.
FAC accepted this audit on March 27, 2017 — management decision was due September 27, 2017.
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