ATLANTIC CITY HOUSING AUTHORITY & URBAN REDEVELOPMENT AGENCYLocal Government

Finding 2025-005: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.EHV Non Compliance - E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 1,056 units. Of a sample size of twenty-four (24) tenant files, the following was noted: - HUD form 9886 was unable to be provided in 6 files - Verification of income was unable to be provided in 2 files - HUD-50058 form was unavailable for review in 4 files - Citizen Declaration Section 214 form was unable to be provided in 9 files - Signed leases were unable to be provided in 8 files - Original application was missing in 2 files - Lead based paint forms were missing 2 files - The Authority was unable to provide 1 tenant file during the time of audit. Known Questioned Costs: $149,640. Cause: There is a material weakness in the Housing Voucher Cluster in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority experienced high turnover and did not properly train employees in the HCV department, which resulted in the Authority having a limited capacity to perform the required maintenance of tenant files, and properly maintain and monitor a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster programs are in material non-compliance with the eligibility requirements of the programs. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on tenant file maintenance so that documents are accumulated, stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the deficiencies in the Housing Voucher Cluster programs and will train staff on the proper maintenance of tenant files and implement internal control procedures that will ensure compliance with federal regulations.

Finding 2025-006: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Inspections. Per the Authority's HCV Admin Plan, the PHA must inspect the unit leased to a family at least annually to determine if the unit meets HQS standards and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). These inspection reports are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management there were inspection reports that were unavailable for examination at the time of audit. Context: Of a sample size of twenty-four (24) units, thirteen (13) units did not have annual HQS inspections performed timely. Our sample size is statistically valid. Known Questioned Costs: $131,112. Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance related to HQS inspections in accordance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the significant deficiency in the Housing Voucher Cluster programs and will implement internal control procedures that will ensure compliance with federal regulations.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 and 14.EHV Noncompliance – N. Special Tests and Provisions – HQS Enforcement Non Compliance Material to the Financial Statements: Yes Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Enforcement. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the Authority must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. If deficiencies are not corrected in the required time period, the Authority must abate housing assistance payments in accordance with their admin plan. Condition: Based upon inspection of the Authority’s files and on discussions with management, the Authority did not provide support for two (2) failed inspections. Context: Of a sample size of two (2) failed inspections, the Authority did not provide support for two (2) failed inspections selected for testing, and did not abate housing assistance payments for the two (2) units selected. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Known Questioned Costs: $31,548 Cause: There is a significant deficiency in internal controls over compliance for the special tests and provisions type of compliance related to HQS enforcement due to high employee turnover. Effect: The Housing Voucher Cluster programs are in material non-compliance with the special tests and provisions type of compliance related to HQS enforcement. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on HQS enforcement that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the deficiencies in the Housing Voucher Cluster programs and has implemented a process to prevent the same issues from occurring. The Authority will also continue to train staff on HQS enforcement and enhance its internal control procedures to ensure compliance with federal regulations.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Non Compliance - E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 1,086 units. Of a sample size of twenty-four (24) tenant files, the following was noted: - Citizenship declaration was missing in 1 file - HUD-9886 form was missing in 5 files - Signed lease was missing in 1 file. Our sample size is statistically valid. Known Questioned Costs: $48,870 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority experienced high turnover and did not properly train employees in the Public and Indian Housing department, which resulted in the Authority having a limited capacity to perform the required maintenance of tenant files, and properly maintain and monitor a system of internal controls that reasonably assures the program is in compliance. Effect: The Public and Indian Housing Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend that the Authority implement a process whereby Authority personnel are hired and trained on tenant file maintenance so that documents are accumulated, stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement.

Finding 2025-009: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 and 14.EHV Noncompliance – N. Special Tests and Provisions - Reasonable Rent Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Reasonable Rent. The Authority must do the following: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract)(24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: Based upon inspection of the Authority’s files and discussion with management, the Authority did not have procedures or software in place to perform the required evaluation of rent reasonableness. Context: There were approximately fifteen(15) newly leased units in the Emergency Housing Vouchers Program. Of a sample size of two (2) newly leased units in the Emergency Housing Vouchers Program, documentation of reasonable rent for the two (2) units was not available for examination. Our sample size is statistically valid. Known Questioned Costs: Unknown Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to reasonable rent. The Authority experienced high turnover and did not properly train employees in the HCV department, which resulted in the Authority having a limited capacity to perform rent reasonableness calculations and properly maintain and monitor a system of internal controls that reasonably assures the program is in compliance with program requirements. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to reasonable rent. Recommendation: We recommend that the Authority procure software and implement a process whereby Authority personnel are hired and trained on performing the appropriate rent reasonableness procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the deficiencies in the Section 8 Housing Voucher Cluster programs and will train staff on rent reasonableness and implement internal control procedures that will ensure compliance with federal regulations.

FINDING #2021-002 ? CONFLICT OF INTEREST - ISSUANCE OF HOUSING CHOICE VOUCHERS Condition During our current year audit, we noted that an employee responsible for approving and issuing Section 8 housing choice vouchers inappropriately issued vouchers to relatives without following required procedures and disclosing a conflict of interest with applicants, thus the vouchers were issued inappropriately and were not in compliance with HUD regulations. Criteria Under HUD regulation 24 C.F.R 982.161 which states: Neither the PHA nor any of its contractors or subcontractors may enter into any contract or arrangement in connection with the housing choice vouchers program in which any of the following classes of persons has any interest, direct or indirect, during tenure or for one year thereafter: ?Any present or former member or officer of the PHA (except a participant commissioner); ?Any employee of the PHA, or any contractor, subcontractor, or agent of the PHA, who formulates policy or who influences decisions with respect to the programs; ?Any public official, member of a governing body, or State or local legislator, who exercises functions or responsibilities with respect to the programs; or ?Any member of the Congress of the United States. In addition to noncompliance with HUD regulations, the employee was also in violation of NJSA 40A:9-22.5, which states: ?No local government officer or employee or member of his immediate family shall have an interest in a business organization or engage in any business, transaction, or professional activity, which is in substantial conflict with the proper discharge of his duties in the public interest.? Cause There was a lack of adequate controls and review process for issuance of vouchers. Effect of Condition Housing choice vouchers issued were not in compliance with HUD regulations. Recommendation We recommend that the Authority implement a secondary review of vouchers to detect any possible conflicts of interest in approved vouchers.

FINDING #2021-003 ? CONFLICT OF INTEREST IN CAPITAL FUND CONTRACTS AWARDED Condition During our current year audit, we noted that a management employee awarded contracts without disclosing a conflict of interest with the awarded party. We noted that contracts were awarded following the correct bidding procedures; however, in one instance a contract was awarded to a company where the management employee had an immediate relative employed with the awarded party. The management employee did not disclose this conflict during the contracting process. Criteria A contract was awarded to a party with a conflict of interest with the employee. The employee was in violation of 24 CFR 85.36 ? Procurement section (b) subsection (3) which states: ?Grantees and sub grantees will maintain a written code of standards of conduct governing the performance of their employees engaged in the award and administration of contracts. No employee, officer, or agent of the grantee or sub grantee shall participate in selection, or in the award or administration of a contract supported by federal funds if a conflict of interest, real or apparent, would be involved.? Cause There was a lack of secondary approval of contracts awarded. Effect of Condition Contract awarded is not in compliance with HUD regulation. Recommendation We recommend that the Authority review and approve all awarded contracts.

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