Windsor Housing AuthorityNon-Profit

2023-002 – ELIGIBILITY Material Weakness/Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871/14.879 – Housing Voucher Cluster CRITERIA PHA responsibility for reexamination and verification. (1) The PHA must conduct a reexamination of family income and composition at least annually. (2) 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: (i) Reported family annual income; (ii) The value of assets; (iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income. (24 CFR 982.516). CONDITION As a result of our audit, we identified the following exceptions in our testing: > Three (3) instances of untimely recertifications CAUSE The Authority did not properly oversee the administration of the Housing Choice Voucher and Mainstream Voucher programs. EFFECT The Authority is potentially incorrectly calculating and adjusting tenant rent and housing assistance payments. QUESTIONED COSTS None identified. CONTEXT We selected a sample of 22 from a population of 200. This was not a statistically valid sample. REPEAT FINDING Repeat of finding 2022-003 RECOMMENDATION We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies. We recommend the Authority provide training for the performance of reexamination procedures. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

2023-003 – REPORTING Material Weakness/Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.871/14.879 – Housing Voucher Cluster 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 HCVP. CONDITION The audited submission was required to be submitted to HUD by September 30, 2024. CAUSE The Authority’s internal control processes were not sufficient to ensure the timely filing of the unaudited FDS. 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 identified. CONTEXT The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing. REPEAT FINDING Repeat of finding 2022-004 RECOMMENDATION We recommend that the Authority ensure its year-end closing process is sufficient to allow for the timely filing of the unaudited FDS. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

2022-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES Material Weakness U.S. Department of Housing and Urban Development CFDA #: 14.871/14.879 – Housing Voucher Cluster CRITERIA Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal Awards: (a) Be necessary and reasonable for the performance of the Federal Award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal Award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 § 200.403) CONDITION As disclosed in Finding 2022-001, the Authority lacked controls over the expenditure and recording of materials and supplies. As such, it is unknown whether or not these expenditures were appropriately charged to the Housing Voucher Program. CAUSE As disclosed in Finding 2022-001, the Authority did not establish an effective control environment or effective control activities over financial reporting or compliance. EFFECT Expenses may have been inappropriately charged to the Housing Voucher Cluster. QUESTIONED COSTS None identified. CONTEXT We reviewed the Authority’s internal controls over compliance with federal awards. REPEAT FINDING Repeat of finding 2021-002 RECOMMENDATION We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

2022-003 – ELIGIBILITY (CONTINUED) Material Weakness/Noncompliance CONDITION As a result of our audit, we identified the following exceptions in our testing:  Six (6) instances of missing release of information  Twelve (12) instances of missing income verifications or insufficient verifications  Thirteen (13) instances of incorrect utility allowance CAUSE The Authority did not properly oversee the administration of the Housing Choice Voucher and Mainstream Voucher programs. EFFECT The Authority is potentially incorrectly calculating and adjusting tenant rent and housing assistance payments. QUESTIONED COSTS None identified. CONTEXT We selected a sample of 20 from a population of 200. This was not a statistically valid sample. REPEAT FINDING This is not a repeat finding. RECOMMENDATION We recommend the Authority’s management take an active role in reviewing their policies and monitoring the Authority’s compliance with those policies. We recommend the Authority provide training for the performance of reexamination procedures. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

2022-004 – REPORTING Material Weakness/Noncompliance U.S. Department of Housing and Urban Development CFDA #:14.871/ 14.879 – Housing Voucher Cluster 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 HCVP. CONDITION The audited submission was required to be submitted to HUD by September 30, 2023. CAUSE The Authority’s internal control processes were not sufficient to ensure the timely filing of the unaudited FDS. 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 identified. CONTEXT The Authority submits the unaudited FDS annually. Our testing of the reporting requirement was limited to the single occurrence of the annual filing. REPEAT FINDING This is not a repeat finding. RECOMMENDATION We recommend that the Authority ensure its year-end closing process is sufficient to allow for the timely filing of the unaudited FDS. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

2021-002 ? INTERNAL CONTROLS OVER COMPLIANCE ? ALLOWABLE COSTS/COST PRINCIPLES Material Weakness/ Other Matter U.S. Department of Housing and Urban Development CFDA #: 14.871/14.879 ? Housing Voucher Cluster CRITERIA Factors affecting allowability of costs. Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 ? 200.403) CONDITION As disclosed in Finding 2021-001, the Authority lacked controls over the expenditure and recording of materials and supplies. As such, it is unknown whether or not these expenditures were appropriately charged to the Housing Voucher Program. CAUSE As disclosed in Finding 2020-001, the Authority did not establish an effective control environment or effective control activities over financial reporting or compliance. EFFECT Expenses may have been inappropriately charged to the Housing Voucher Cluster. QUESTIONED COSTS None identified. CONTEXT All expenditures of federal programs are subject to cost principles. REPEAT FINDING Repeat of finding 2020-002. RECOMMENDATION See Finding 2021-002. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

2020-002 ? INTERNAL CONTROLS OVER COMPLIANCE ? ALLOWABLE COSTS/COST PRINCIPLES Material Weakness/Other Matter U.S. Department of Housing and Urban Development CFDA #: 14.871/14.879 ? Housing Voucher Cluster CRITERIA Factors affecting allowability of costs. Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non- Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this Part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. (g) Be adequately documented. (2 CFR Chapter 1 Part 200 ? 200.403) CONDITION As disclosed in Finding 2020-001, the Authority lacked controls over the expenditure and recording of materials and supplies. As such, it is unknown whether or not these expenditures were appropriately charged to the Housing Voucher Program. CAUSE As disclosed in Finding 2020-001, the Authority did not establish an effective control environment or effective control activities over financial reporting or compliance. EFFECT Expenses may have been inappropriately charged to the Housing Voucher Cluster. QUESTIONED COSTS None identified. CONTEXT All expenditures of federal programs are subject to cost principles. REPEAT FINDING Not a repeat finding. RECOMMENDATION See Finding 2020-001. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan

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