KINGSTON HOUSING AUTHORITY

2022-002 – Reporting U.S. Department of Housing and Urban Development 14.871 – Housing Choice Vouchers Cluster L. Reporting – Compliance Finding – Significant Deficiency Condition: During review of the Housing Choice Voucher program, RBT noted that the PHA did not submit timely GAAP-based unaudited and audited financial information to HUD after year end, within two and a half months for unaudited, and nine months for audited. Criteria: As a condition of receiving federal awards, the PHA agrees to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal controls to provide reasonable assurance of compliance with these requirements. Cause: The PHA did not have appropriate audit ready information/documentation in place in order for the unaudited FDS submission and audit to be conducted in a timely manner. Effect: Potential loss of funding due to noncompliance. Questioned Costs: None identified. Perspective: This is a systemic issue. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the PHA prepares all required information/documentation to ensure that the Authority can submit the unaudited and audited financial information to HUD timely. Auditee’s Response: See corrective action plan.

2022-003 – HQS Enforcement U.S. Department of Housing and Urban Development 14.871 – Section 8 Housing Choice Vouchers N. Special Tests and Provisions – HQS Enforcement – Significant Deficiency and Compliance Finding Condition: During review of the Housing Choice Voucher program, RBT noted that the Authority was not appropriately maintaining the listing of failed inspections to ensure follow up in accordance with HQS Enforcement. Criteria: As a condition of receiving federal awards, the PHA agrees to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal controls to provide reasonable assurance of compliance with these requirements. Cause: The Authority does not maintain a listing of failed HQS inspections to ensure proper HQS Enforcement. Effect: Potential noncompliance if a control is missed. Questioned Costs: None identified. Perspective: This is a systemic issue. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Authority establish a weekly/monthly list for the Tenant Housing Representative to use during the HQS inspection process to ensure all failed inspections are followed up and corrected timely. The list should be signed or initialed by the representative weekly/monthly to track and maintain the status of all HQS inspections. This checklist will serve as documentation that all HQS have been met. Auditee’s Response: See corrective action plan.

2022-004 – Tenant Files U.S. Department of Housing and Urban Development 14.871 – Section 8 Housing Choice Vouchers Cluster E. Eligibility and N. Special Tests and Provisions – Significant Deficiency and Compliance Finding Condition: During review of the Housing Choice Voucher tenant files, RBT noted incomplete file documentation. RBT also noted that the Authority was not appropriately documenting the controls over Eligibility, Reasonable Rent, Utility Allowance, and HQS Inspections. Criteria: As a condition of admission or continued occupancy, PHAs must require the tenant and applicable family members to provide necessary information and releases for the PHA to verify income eligibility and obtain and document the family third-party verification of reported family income during annual reexamination of family income or during move-in. Additionally, as a condition of receiving federal awards, the PHA agrees to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal controls to provide reasonable assurance of compliance with these requirements. Cause: The Authority does not have a central, uniform location to document the controls in place over Eligibility, Reasonable Rent, Utility Allowance and HQS Inspections. Effect: Potential loss of funding due to noncompliance or additional noncompliance if a control is missed. Questioned Costs: None identified. Perspective: Of the 25 tenant files tested, 2 files had incomplete forms HUD-9886, 1 file had no EIV third-party income verification, 1 file had an incomplete HQS inspection, and all 25 tenant files tested were missing documentation of internal controls. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Authority establish a checklist for the Tenant Housing Representative to use during the recertification process to ensure all compliance requirements are met. The checklist should be signed or initialed by the representative and maintained in the tenant’s file. This checklist will serve as documentation that all compliance requirements were verified for the tenant. Auditee’s Response: See corrective action plan.

2022-005 – Tenant Files U.S. Department of Housing and Urban Development 14.850 – Public and Indian Housing E. Eligibility – Significant Deficiency and Compliance Finding Condition: During review of the Public and Indian Housing program, RBT noted incomplete file documentation. RBT also noted the Authority was not appropriately documenting controls over Eligibility and Environmental Contaminants and Remediation. Criteria: As a condition of receiving federal awards, the PHA agrees to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal controls to provide reasonable assurance of compliance with these requirements. Cause: The Authority does not have a central, uniform location to document the controls in place over Eligibility, Reasonable Rent, Utility Allowance, and HQS Inspections. Effect: Potential noncompliance if a control is missed. Questioned Costs: None identified. Perspective: Of the 15 tenant files tested, 4 files had an incomplete form HUD-9886 and all 15 files selected for testing were missing documentation of internal controls. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Authority establish a checklist for the Tenant Housing Representatives to use during the recertification process to ensure all compliance requirements are met. The checklist should be signed or initialed by the representative and maintained in the tenant’s file. This checklist will serve as documentation that all compliance requirements were verified for the tenant. Auditee’s Response: See corrective action plan.

2022-006 – Recording of Declarations of Trust Against Public Housing Property U.S. Department of Housing and Urban Development 14.850 – Public and Indian Housing N. Special Tests and Provisions – Significant Deficiency and Compliance Finding Condition: During review of Public and Indian Housing program, RBT noted that the Authority could not locate the Declaration of Trust documents for all properties owned by the Authority and, therefore, the status of the documents was indeterminable. Criteria: A current Declaration of Trust (DOT) in a form acceptable to HUD, must be recorded against all public housing property owned by PHAs that has been acquired, developed, maintained, or assisted with funds from the US Housing Act of 1937. Cause: The Authority did not have controls in place over Declaration of Trusts sufficient to ensure the appropriate documents are current, recorded, and maintained for all properties owned by the Authority. Effect: The Authority is not in compliance with the Declaration of Trust requirement of the program. Questioned Costs: None identified. Perspective: The Authority could not locate a current DOT for any of the three properties selected for testing. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Authority complete and maintain a Declaration of Trust in a form acceptable by HUD for all properties of the Authority and that the Authority establish controls over Declarations of Trust to ensure the forms are completed and current in the future. Auditee’s Response: See corrective action plan.

2022-007 – Procurement, Suspension, and Debarment U.S. Department of Housing and Urban Development 14.850 – Low Rent Public and Indian Housing I. Procurement, Suspension, and Debarment – Significant Deficiency Condition: The Authority did not have sufficient internal controls over debarment. Criteria: Federal expenditure debarment requirements provide for internal controls to ensure federal funds are not used to pay contractors that are debarred. Cause: The Authority did not have policies in place to document review of contractors for suspension and debarment. Effect: Suspension and debarment were not verified. Questioned Costs: None identified. Perspective: This is a systemic issue. Repeat Finding: Not a repeat finding. Recommendation: RBT recommends that the Authority review its internal controls process for procurement and revise the procurement policy to include documenting suspension and debarment procedures when awarding contracts. Auditee’s Response: See corrective action plan.

GSA_MIGRATION