SYRACUSE HOUSING AUTHORITY

Criteria - Fiscal closeout of a CFP grant includes the submission of a cost certificate; a final Performance & Evaluation Report (P&E Report); HUD approval of the cost certificate; and an audit, if applicable. In order to initiate the closeout process, the Authority shall submit the Field Office the Actual Modernization Cost Certificate (AMCC) (Form HUD-53001) and the P&E Report (Form HUD-50075.1). Per 2 CFR 200.343, these reports are to be submitted within 90 days after the funds are expended. Condition - The Authority did not submit the AMCC and P&E Report within 90 days after the funds were expended for Public Housing Capital Fund Grants NY06P001501-17 and NY06P001501-18. The funds were fully expended on February 12, 2021 and August 25, 2021, respectively. Cause - The Authority?s grant reporting procedures were not sufficient to ensure compliance with requirements. Effect - The Authority did not submit timely. Questioned Costs - None identified. Recommendation - We recommend the Authority complete and submit the AMCC in a more timely manner immediately following the final request from the electronic line of credit control system (eLOCCS) and familiarize themselves with the "Capital Fund Guidebook" for reporting requirements to ensure accurate and timely grant reporting in compliance with grant agreements. Management?s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action taken. (b) Action taken - Closeout of CFP grants and all related reports will be handled by the Comptroller and CFO on a going forward basis in a timely manner subsequent to the grant being fully expended. The Authority will also familiarize ourselves with the Capital Fund Guidebook to ensure reporting requirements are being met. (c) Planned implementation date of correct action - Completed by June 30, 2023

Criteria - HUD?s Uniform Financial Reporting Standards (UFRS) Rule (24 CFR ?5.801) requires Authorities to submit annual financial data to HUD. Specifically, UFRS requires that the financial data is: 1) prepared in accordance with Generally Accepted Accounting Principles (GAAP) as further defined by HUD in supplementary guidance; 2) submitted electronically to HUD through the internet; and 3) submitted in such form and substance as prescribed by HUD. As a separate funding source, the EHV supplemental funding (Assistance Listing No. 14.871) must be reported separately on the Financial Data Schedule (FDS). Additionally, any unspent service fees must be reported as restricted cash and unearned revenue. Condition - Prior to audit, the Authority did not properly present a statement of net position and statement of revenue, expenses and changes in net position for EHV using 14.EHV reporting column for the year ended June 30, 2021 in the FDS. All of the activity related to EHV was commingled with the Authority's Housing Choice Voucher Program (HCV) (14.871). Effect - The Authority's activity in the HCV program was overstated by the activity related to EHV. Additionally, total EHV revenue was overstated by $92,750 related to unspent service fees as of June 30, 2021. Questioned Costs - None identified. Recommendation - We recommend the Authority review all compliance requirements and HUD notifications for all new funding sources, specifically, PIH Notice 2021-25 related to proper reporting of the supplemental EHV funds. Management?s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action taken. (b) Action taken - The Authority?s accounting staff has created new general ledger accounts to record the Emergency Housing Voucher Program separately from the Section 8 Housing Choice Voucher Program. (c) Planned implementation date of corrective action - Completed by June 30, 2022.

Condition - For the Public and Indian Housing Program, 20 applicants were selected for testing the waiting list compliance requirement. Out of the 20 applicants selected, none were notified in writing of placement on the waiting list or the approximate wait before housing may be offered, as required by the Authority?s policies.Criteria - The Authority must establish and adopt written policies for admission of tenants. The Authority tenant selection policies must include requirements for applications and waiting lists, description of the policies for selection of applicants from the waiting lists, and policies for verification and documentation of information relevant to acceptance or rejections of an applicant.Effect - The Authority is not following its own written policy.Recommendation - The Authority should either amend its waiting list policy or review its written policies to ensure each family is notified in writing of placement on the waiting list, and the approximate wait before housing may be offered.Management?s Response - Years ago, SHA changed its application process. Formerly, people applied, were prescreened, then if found eligible, were placed on SHA?s wait list. They were notified that they had passed the prescreening phase and were included on the list. The current system is to automatically include all who apply on the wait list and screen the individuals as they near the front of the list. Under this scenario the mere fact that you applied serves as notice that they are placed on the wait list. The most recent policy found stating the old methodology wasSHA?s 2013 ACOP. SHA could not find where it had memorialized its new procedure. It did so in the new ACOP which was approved by the Board of Directors at its October 2019 Board meeting.

Condition - Out of 60 tenant files tested in the Housing Choice Voucher Program, four selections did not contain a citizenship declaration and one selection did not contain documentation of ceased benefits for uncorrected failed inspections within thirty days of notice.Criteria - Eligibility for a housing voucher is limited to US citizens and specified categories of noncitizens who have eligible immigration status. Additionally, the Authority must inspect units leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension.Effect - No evidence that the four tenants in question were US citizens or specified categories of non-citizens who have eligible immigration status. Regarding inspections, the Authority continued to provide housing assistance payments (HAP) even after the thirty day specified period.Recommendation - The Authority should review all tenant file retention and inspection policies and procedures with key staff involved within the process and conduct training for aid in the proper retention of documents. Additionally, the Authority should perform inspections in accordance with HUD?s compliance requirements. For situations where HQS deficiencies are not corrected, the Authority should stop HAPs beginning no later than the first of the month following the specified correction period or terminate the HAP contract.Management?s Response - While SHA made significant strides in improving its quality control checks regarding its 3500+ Housing Choice Voucher files during Fiscal 2019 (versus the large number of issues cited as part of the Fiscal 2018 audit finding), SHA acknowledges there is always room for improvement and will continue to enhance its file review process.

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