Housing Authority of the City of PatersonLocal Government

Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871 & 14.EHV Noncompliance – 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). Finding 2025-001 (continued) 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 and the Authority included income that was miscalculated during the annual recertification. Context: Of a sample size of thirty-seven (37) tenant files, the following information was unavailable for examination at the time of audit: • Original application was missing in one (1) file • Citizenship declaration was missing in one (1) file • Signed lease was missing in one (1) file • Verification of income was missing in four (4) files • HUD form 50058 was not timely filed for one (1) file In addition, three (3) tenants' annual recertifications (HUD-50058 form) included income that was miscalculated. Our sample size is statistically valid. 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 has not properly considered and designed a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure eligibility compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster Program to ensure that established internal control policies are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.

Finding 2025-002 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: No Significant deficiency in Internal Control over Compliance for Special Tests and Provisions Finding 2025-002 (continued) Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) 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. For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were units that were not inspected within the annual inspection period. Additionally, there were units that failed inspections and did not pass reinspection within 30 days without penalty. Context: There are approximately two thousand seven hundred fifty six (2,756) units. Of a sample size of thirty seven (37) files, three (3) annual inspections, were not completed in a timely manner. Additionally, there are approximately one thousand two hundred forty seven (1,247) units with failed inspections. Of a sample size of twenty five (25) units with failed inspections, four units (4) unit did not pass reinspection within 30 days. Housing assistance payments were not abated nor was the tenant relocated. Our sample size is statistically valid. Cause: The Authority did not perform timely annual inspections and follow up to failed inspections in accordance with program requirements. Effect: The Housing Voucher Cluster Program is in 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. Authority's Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies related to HQS inspections are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.

2024-002

Finding 2025-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Internal Control over Compliance for Eligibility Finding 2025-003 (continued) 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 and the Authority failed to properly calculate the tenant's rent payments using documentation from third party income verification. Context: There are approximately 834 units. Of a sample size of twenty three (23) tenant files, the following was noted: Original Applications were missing in thirteen (13) files. Citizenship Declarations were missing in five (5) files. Verification of income was missing in eight (8) files. The Authority also failed to properly calculate the rent payments of four (4) tenants by not utilizing documentation from third party income verification. Our sample size is statistically valid. 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 and the calculation of rent. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure eligibility compliance with the Uniform Guidance and the compliance supplement. Authority's response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Voucher & Emergency Housing Vouchers Assistance Listing Number: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Material to the Financial Statements: Section 8 Housing Choice Vouchers - Yes Emergency Housing Vouchers - No Material Weakness and Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions. Criteria: Housing Quality Standards Inspections. 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 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)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussions with management, the Authority did not properly abate fifteen (15) out of twenty-nine (29) annual failed inspections selected for testing. Context: The Authority did not properly abate fifteen (15) out of twenty-nine (29) failed inspections selected for testing. 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). Our sample size is statistically valid. Known Questioned Costs: Section 8 Housing Choice Vouchers $50,873 Emergency Housing Vouchers $1,308 Cause: There is a material weakness in Section 8 Housing Choice Vouchers and a significant deficiency in Emergency Housing Vouchers in internal controls over 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 Section 8 Housing Choice Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to HQS inspections and the Emergency Housing Vouchers Program is in non-compliance 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 assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: We agree with the Auditor’s observations on the re-inspection of the failed units. The Authority had an independent contractor whose contract was terminated due to their unacceptable performance with HQS inspections. As a result, two HQS inspectors were recently hired, and a clerical person to assist in improving the quality control component of the program as it relates to HQS inspections. In addition, the Authority recently hired a Director of Leasing and Occupancy, and a Supervisor of the department, and has implemented a more stringent oversight to ensure that internal control policies are being followed in a timely manner to show improvement in this area, and an overall improvement to the entire function of this department. We are also actively seeking to fill two vacant Tenant Interviewer/Investigator positions. The current staffing change mentioned above puts the agency in a position to implement and ensure a tracking system being able to capture areas on Annual HQS unit status, First Inspection if failed for life threatening HQS deficiencies rescheduled within 24 hours and 30 days for all other deficiencies. Abatements are placed on all units having two failed HQS inspections. All current occupied units are being reviewed for HQS inspection status, and a resolving issues to those units not in compliance with the program. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2025.

2023-003

Finding 2023-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Emergency Housing Vouchers Assistance Listing Number: 14.EHV Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant deficiency 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). Condition: Based upon inspection of the Authority’s files and on discussions with management there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of six (6) tenant files, the following information was unavailable for examination at the time of audit: • Annual 50058 form • Annual inspection form Our sample size is statistically valid. Known Questioned Costs: $1,775 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered and designed a system of internal controls that reasonably assures the program is in compliance. Effect: The Emergency Housing Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: We agree with the Auditor’s observations on the inspection of the tenant files and will implement internal control procedures that will assure tenant file compliance. Views of responsible officials and planned corrective action: The PHA has taken into consideration the Auditor’s recommendation in regards to Emergency Housing Vouchers (EHV) program. During the audit period, the staff assigned to the EHV program changed three times, resulting in program deficiencies. Currently a more skilled tenant interviewer is responsible for voucher processing, therefore program compliance will be in line with HUD requirement.

2022-002

Finding 2023-003: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Voucher Assistance Listing Number: 14.871 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: Housing Quality Standards Inspections. 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 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)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussions with management, the Authority did not properly abate thirteen (13) out of twenty-five (25) annual failed inspections selected for testing. Context: The Authority did not properly abate thirteen (13) out of twenty-five (25) failed inspections selected for testing. 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: $66,242 Cause: There is a material weakness in internal controls over 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 Section 8 Housing Choice Vouchers Program is in material non-compliance 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 assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: We agree with the Auditor’s observations on the re-inspection of the failed units. Based on the auditor’s recommendation, the Authority will implement a more stringent oversight to ensure that internal control policies are being followed in a timely manner to show improvement in this area. In addition, the Authority has recently hired a HQS inspector in the Leasing and Occupancy department, which will assist to improve the quality control component of the program. Further the Authority is actively seeking to fill the vacant Director and Supervisor positions in the L&O department, to improve the entire operation function of this department.

Corrective Action Plan For the year ended March 31, 2022 U.S. Department of Housing and Urban Development: The Housing Authority of the City of Paterson respectfully submits the following corrective action plan for the year ended March 31, 2022. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River, New Jersey 08753 The findings from the March 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Financial Statement Findings Reference 2022-001: Criteria: In accordance with N.J.S.A. 46:30B and the Uniform Unclaimed Property Act of the State of New Jersey, all property, including any income or increment derived there from, less any lawful charges, whether located in this state or another state, that is held, issued, owing in the ordinary course of a holder's business and has remained unclaimed by the owner for more than three years after it became payable or distributable is presumed abandoned, and is subject to custody of the state as unclaimed property. Additionally, HUD requires PHA?s to conform to state escheatment laws related to unclaimed tenant utility reimbursements. Condition: The Authority has unclaimed property in stale dated checks that meet that State?s definition. Reference 2022-001 (continued) Context: During our audit, we noted several checks that were either outstanding for greater than a three-year period or determined to be stale dated by management. These checks were made up of housing assistance payments and utility reimbursements, and were recorded as a liability in the Section 8 Housing Choice Vouchers Program. HUD?s regulations require the Authority to follow the State?s escheat laws, which would require the Authority to ultimately consider these checks as unclaimed property, and turn them over to the State Treasurer. Known Questioned Costs: N/A Cause: The Authority did not properly consider state and federal regulations related to unclaimed property. Effect: Due to the stale dated checks being outstanding for greater than a three-year period, they are to be considered unclaimed property in the State of New Jersey. The Authority did not properly identify these outstanding checks as unclaimed property, or follow the proper reporting requirements of the State of New Jersey. Additionally, no stale dated checks were escheated to the State. Recommendation: The Authority should draft and adopt a method of complying with reporting requirements related to unclaimed property in accordance with the State of New Jersey Statutes. Authority Response: The Authority accepts the recommendation of the auditor and has made arrangements to comply with the State of New Jersey Statutes. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor and has made arrangements to comply with the State of New Jersey Statutes. Irma Gorham is responsible to remedy the deficiency by March 31, 2023. Federal Award Findings and Questioned Costs Finding 2022-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant deficiency 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). Finding 2022-002 (continued): Condition: Based upon inspection of the Authority?s files and on discussions with management there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of thirty-six (36) tenant files, the following information was unavailable for examination at the time of audit: ? Verification of income and assets was missing in one (1) file Our sample size is statistically valid. Known Questioned Costs: $11,054 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered and designed a system of internal controls that reasonably assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: We agree with the Auditor?s observations on the inspection of the tenant files and will implement internal control procedures that will assure tenant file compliance. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the Section 8 Housing Choice Vouchers Program. Irma Gorham is responsible to remedy the deficiency by March 31, 2023. Schedule of Prior Year Audit Findings Reference 2021-001: Observation: During our audit, we noted several checks that were either outstanding for greater than a three-year period or determined to be stale dated by management. These checks were made up of housing assistance payments and utility reimbursements, and were recorded as a liability in the Section 8 Housing Choice Vouchers Program. HUD?s regulations require the Authority to follow the State?s escheat laws, which would require the Authority to ultimately consider these checks as unclaimed property and turn them over to the State Treasurer. Reference 2021-001 (continued): Status: The finding remains open. See Finding 2022-001 above. Sincerely yours, Irma Gorham Executive Director

Corrective Action Plan For the year ended March 31, 2019 U.S. Department of Housing and Urban Development: The Housing Authority of the City of Paterson respectfully submits the following corrective action plan for the year ended March 31, 2019. Auditor: Novogradac and Company, LLP Certified Public Accountants 1433 Hooper Avenue Suite 329 Toms River, New Jersey 08753 The findings from the March 31, 2019 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Federal Award Findings and Questioned Costs Reference 2019-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Material Noncompliance - E. Eligibility- Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files (Section 8 Housing Choice Vouchers Program) - 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 a significant number of documents that were unavailable for examination at the time of audit. Context: There are approximately 2,54 l units. Of a sample size of 41 tenant files, the following was noted: The lead based paint form was missing in 5 files The signed lease was missing in 7 files Rent reasonableness documentation was missing in 5 files Verification of income was missing in 4 filed Our sample size is statistically valid. Known Questioned Costs: $195,670 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 has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. The non-compliance is also material to the financial statements. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The affected files relate to clients that have been on the program for decades and as files get large, archiving takes place. To correct this finding, a directive will be issued to staff that will ensure that when files are archived the original application must be placed in the current working file going forward. Dale Jones is responsible to remedy the deficiency by March 31, 2020.

2018-002

Corrective Action Plan For the year ended March 31, 2019 U.S. Department of Housing and Urban Development: The Housing Authority of the City of Paterson respectfully submits the following corrective action plan for the year ended March 31, 2019. Auditor: Novogradac and Company, LLP Certified Public Accountants 1433 Hooper Avenue Suite 329 Toms River, New Jersey 08753 The findings from the March 31, 2019 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Federal Award Findings and Questioned Costs Reference 2019-003: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance- N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. 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 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)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority's files and on discussion with management, there were units that had not passed re-inspection within the required thirty day period and abatements had not been processed for those units. Context: Of a sample size of 40 units that had initially failed inspection, three (3) units did not pass re-inspection within 30 days. HAP abatements were either not processed or not processed in accordance with Program compliance requirements for those three (3) units. Our sample size is statistically valid. Known Questioned Costs: $7,029 Cause: There is a significant deficiency 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 Section 8 Housing Choice Vouchers Program is in non-compliance 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 assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: We agree with the Auditor's observations on the re-inspection of the failed units. However, the PHA must implement more oversight to ensure that the internal control policies are being followed in a timely manner to show improvement in this area. The PHA has recently hired a supervisor in this department to improve the quality control of the program. Dale Jones is responsible to remedy the deficiency by March 31, 2020.

2018-003

GSA_MIGRATION

2017-001

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2017-002

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2017-003

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2016-001

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2016-002

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2016-003

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2015-001

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2015-001

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