BROOKLINE HOUSING AUTHORITY

The Brookline Housing Authority (BHA) takes seriously all audit deficiencies. Immediate corrective action has and will be taken after Marcum LLP notified the BHA of this issue during the FY ?22 audit process. Specific details of how the BHA intends to address this finding are detailed below. 2022-001 ? Procurement, Suspension & Debarment For procurements of $10,000 or more, there shall be maintained a written record which includes the contract and any amendments to the contract. If a contract is awarded pursuant to a formal solicitation, the written record shall also include the invitation for bids or request for proposals, the public notices and advertisements, the bids or proposals submitted and written evaluation of proposals. All written documentation required by this Section shall be maintained for a period of six years from the date of final payment under the contract. (Brookline Housing Authority Procurement Policy) As a result of not adequately documenting the procurement decision, the Authority has not complied with their procurement policy and cannot ensure that it is receiving the most competitive prices or rates for services that have been procured. Auditee?s Response and Planned Corrective Action The BHA made strides during FY 2022 and strives to continue to prioritize contract and procurement practices that comply with applicable state (M.G.L 30B) and federal regulations. There was one issue, with one particular vendor that gave rise to this finding. The BHA Board of Commissioners approved an updated procurement policy as recommended by the Executive Director in the 1st quarter of FY 2022. This policy is compliant with both state and federal procurement guidelines but also contains additional controls on spending thresholds to ensure competitive contracting beyond regulatory requirements. The BHA already maintained records for six or more years from the date of final procurement for procurements $10,000 or larger. However, it did not have consistent record retention of small vendors that were used repeatedly under this $10,000 threshold and where bids could be solicited without an RFP. Going forward these records will be retained for repeatedly used vendors. The Director of Maintenance and Modernization has already been systematically re-procuring trades like electrical and painting in late FY 2022 and throughout FY 2023 where this was an issue and within a calendar year should fully re-procure all applicable services. The BHA is also planning to make the following immediate corrective actions and changes to internal controls: 1. The Director of Operations and Director of Maintenance and Modernization have both become certified Procurement Officers for the Brookline Housing Authority. 2. The Director of Operations, Director of Finance, and Executive Director will periodically review expenditures for frequently recurring transactions that could exceed competitive procurement thresholds. 3. The Director of Operations, Director of Finance, and Executive Director will periodically compare the contract register against frequently used vendors. 4. The BHA already retains a contract register and procurement details for competitive procurements over $10,000. The BHA will require all staff to retain solicitation records and materials used to make a procurement decision for smaller contracts and enter recurring contractors into the contract log. Planned Implementation Date of Corrective Action: November 28, 2022. Persons Responsible for Corrective Action: Michael Alperin, Executive Director, Lisa Brown, Director of Operations, Chris Devoll, Director of Maintenance and Modernization and John Kelley, Director of Finance. (617)-277-2022

2021-001

The Brookline Housing Authority (BHA) takes seriously all audit deficiencies. Immediate corrective action has and will be taken after Marcum LLP notified the BHA of these issues December 15, 2021. Specific details of how the BHA intends to address each finding are detailed below. 2021-001 ? Procurement, Suspension & Debarment For procurements of $10,000 or more, there shall be maintained a written record which includes the contract and any amendments to the contract. If a contract is awarded pursuant to a formal solicitation, the written record shall also include the invitation for bids or request for proposals, the public notices and advertisements, the bids or proposals submitted and written evaluation of proposals. All written documentation required by this Section shall be maintained for a period of six years from the date of final payment under the contract. (Brookline Housing Authority Procurement Policy) As a result of not adequately documenting the procurement decision, the Authority has not complied with their procurement policy and cannot ensure that it is receiving the most competitive prices or rates for services that have been procured. Auditee?s Response and Planned Corrective Action The BHA has and continues to prioritize contract and procurement practices that comply with applicable state (M.G.L 30B) and federal regulations. Prior to the issuance of the FY 2021 audit the BHA Board of Commissioners approved an updated procurement policy as recommended by the Executive Director on June 8, 2021. This policy is compliant with both state and federal procurement guidelines but also contains additional controls on spending thresholds to ensure competitive contracting beyond regulatory requirements. The BHA already maintained records for six or more years from the date of final procurement for procurements $10,000 or larger. However, it did not have consistent record retention of small vendors that were used repeatedly under this $10,000 threshold and where bids could be solicited without an RFP. Going forward these records will be retained for repeatedly used vendors. The BHA is also planning to make the following immediate corrective actions and changes to internal controls: 1. The Director of Operations will attend state and federal trainings to become a certified Procurement Officer for the Brookline Housing Authority. 2. The Director of Operations, Director of Finance, and Executive Director will periodically review expenditures for frequently recurring transactions that could exceed competitive procurement thresholds. 3. The Director of Operations, Director of Finance, and Executive Director will periodically compare the contract register against frequently used vendors. 4. The BHA already retains a contract register and procurement details for competitive procurements over $10,000. The BHA will require all staff to retain solicitation records and materials used to make a procurement decision for smaller contracts and enter recurring contractors into the contract log. Planned Implementation Date of Corrective Action: June 8, 2021 (new procurement policy) and December 22, 2021. Person Responsible for Corrective Action: Michael Alperin, Executive Director, Lisa Brown, Director of Operations, Chris Devoll, Director of Maintenance, and John Kelley, Director of Finance.

2021-002 ? Eligibility Other Matter/Significant Deficiency The Authority is mandated to use HUD?s Enterprise Income Verification (EIV) system as a third party source to verify tenant employment and income information during mandatory reexaminations or recertification of family composition or income. (24 CFR 5.233) The Auditors examined a sample of 25 participants in the Public Housing Program and identified 4 instances in which the EIV report was not used to verify tenant employment and income information. Auditee?s Response and Planned Corrective Action FY 2021 was a challenging year for Property Managers due to the volume of income recertifications caused by the Coronavirus Pandemic, temporary remote work environment caused by the Coronavirus Pandemic, and guidance from HUD which temporarily changed programmatic procedures due to CARES Act waivers and other federal stimulus measures. Regardless of the macro environment, the BHA strives to have 100% accurate files in its Public Housing Program and takes seriously the finding of EIV report issues. The BHA is planning to make the following immediate corrective actions and changes to internal controls: 1. Pay for and require all Property Managers and Assistant Property Managers to attend (reattend) EIV and Income Qualification Trainings hosted by Nan McKay or an equivalent consultant. 2. Establish written procedures related to using HUD?s Enterprise Income Verification System (EIV) and a checklist for all Federal Public Housing certifications. This checklist will be included in each tenant file and used to ensure completeness. 3. Communicate to all Property Managers and Assistant Property Managers performing recertifications that they are required to utilize the EIV system. 4. The Director of Property Management will select a minimum of 10% of recertifications completed each month to perform quality control reviews to ensure that EIV and checklists are being used. Planned Implementation Date of Corrective Action: December 22, 2021 and upon recertification at each property according to schedule below. Development Deadline for Delivering Recert Packets Deadline for 14/30 Day Notice of Rent Change Effective Date of Rent Change KICKHAM 190 Harvard St. August 31st November 30th January 1st COL. FLOYD Foster/Marion St October 31st January 31st March 1st SUSSMAN 50 Pleasant St January 31st April 30th June 1st ? HIGH ST. VETS 176-212 High St. All of New Terrace Rd. February 28th May 31st July 1st TRUSTMAN Amory St., Egmont St., St. Paul St. March 31st June 30th August 1st WALNUT STREET 22 High St., Walnut St May 31st August 31st October 1st ? EGMONT STREET VETS 60s, 70s & 80s bldgs. May 31st August 31st October 1st ? EGMONT STREET VETS Pleasant; St Paul & 50s bldg. June 30th September 30th November 1st ? HIGH ST. VETS 214-224 High & All of Chestnut St June 30th September 30th November 1st Person Responsible for Corrective Action: Ana De La Puente, Director of Property Management

2021-003 ? Eligibility Other Matter/Significant Deficiency 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 (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 the auditors procedures the following was noted: ? Four instances in which the Authority obtained sufficient verifications of participant?s income; however, the participant?s annual income was calculated incorrectly. ? One instance of missing verification of participant?s income ? Estimated questioned costs are less than $25,000. Auditee?s Response and Planned Corrective Action FY 2021 was a challenging year for the BHAs Section 8 Department due to the volume of income recertifications caused by the Coronavirus Pandemic, temporary remote work environment caused by the Coronavirus Pandemic, and guidance from HUD which temporarily changed programmatic procedures due to CARES Act waivers and other federal stimulus measures. Additionally, the BHA temporarily relocated files due to its office renovation. The potential for file disruption during the move was compounded by the temporary suspension of SEMAP by HUD which paused the Director of Leased Housing and Assistant Director of Leased Housing?s normal file audit process. Nevertheless, the BHA always strives to have 100% accurate files in its Section 8 Program and takes seriously the finding of verification and income calculation issues. The BHA is planning to make the following immediate corrective actions upon recertification and changes to internal controls: 1. Pay for and require all staff to attend a Nan McKay or an equivalent consultant training. 2. Ensure a recertification checklist is included at the front of each file (and update this checklist with a consultant if appropriate). 3. Communicate to staff that they are required to check-off each part of the recertification checklist and include an income calculation worksheet to ensure file completeness and accuracy. 4. The Director of Leased Housing and Assistant Director of Leased Housing will select a minimum of 10% of recertifications (11+) completed each month as of January 2022 to perform quality control reviews to ensure that files are complete, and income is calculated accurately. This is above and beyond the SEMAP audit requirement to which the Director of Leased Housing already adheres. Planned Implementation Date of Corrective Action: December 22, 2021 and upon recertification Person Responsible for Corrective Action: Carlos Hernandez, Director of Leased Housing