HOUSING AUTHORITYLocal Government

Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Federal Assistance Listing Numbers: 14.871 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). 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 three hundred forty five (345) Section 8 Housing Choice Voucher units. Of a sample size of fifteen (15) tenant files, the following information was unavailable for examination at the time of audit:  Original applications were missing in six (6) files  Citizenship declaration forms were missing in three (3) files  Lead based paint form was missing in one (1) file  Copy of signed lease was missing in three (3) files  Verification of income and assets was missing in two (2) files Our sample size is statistically valid. Known Questioned Costs: Amount is below threshold of $25,000. 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 reasonably 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. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement.

Finding 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Federal Assistance Listing Numbers: 14.871 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 discussions with management, there were newly leased units for which rent reasonableness evaluations were not performed. Context: There were approximately seventeen (17) newly leased Section 8 Housing Choice Voucher units. Of a sample size of two (2) newly leased units, rent reasonableness evaluations for one (1) unit was not performed. Our sample size is statistically valid. Known Questioned Costs: Amount is below threshold of $25,000. 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. Existing controls were not properly designed, implemented, or maintained to ensure that rent reasonableness requirements are consistently met. 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 the Authority design and implement internal control procedures that ensure all rent reasonableness determinations are performed and documented, in compliance with Uniform Guidance and the compliance supplement.

Finding 2025-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Federal Assistance Listing 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 biennially 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 failed inspections that did not pass reinspection within 30 days without penalty. Context: There were approximately eleven (11) Section 8 Housing Choice Vouchers units with failed inspections. Of a sample size of two (2) failed inspections, two (2) failed inspections did not pass reinspection within 30 days. Housing assistance payments were not abated nor was the tenant relocated. Our sample size is statistically valid. Known Questioned Costs: Amount is below threshold of $25,000. 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 performed annual HQS inspections in compliance with program requirements. Effect: The Section 8 Housing Choice Vouchers program is in non-compliance with the eligibility type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement.

Finding 2024-001 Low Rent Public Housing (CFDA#14.850) Type of Deficiency: Material Weakness Compliance Requirement: Eligibility and Special Tests We selected forty files for the Low Rent Public Housing Program. 5 of the files were missing required documentation from EIV, and one was missing an interim recertification. Cause: The Authority did not implement the proper controls to ensure that all tenants are properly recertified each year. Condition: The Authority did not follow the compliance requirements of 24CFR sections 5.230, 5.609 and 960.259. This was condition was noted as a finding the prior year audit report. Effect of Condition: The effect of not complying with the requirements in the Compliance Supplement may result in ineligible individuals being admitted to the program and improper rent calculations. Recommendation: We recommend that the Authority adopt controls and procedures to ensure compliance with the requirements of the Low Rent Public Housing Program. Questioned Costs -$0- Response: The following steps have been and are being taken regarding tenant certifications: 1. We issued a Request for Proposals for a third-party Contractor to perform all recertifications. We intend to award this Contract in July 2025. 2. All Managers and assistant Managers will use the third-party Contractor to learn proper recertification and documentation procedures.

Housing Choice Voucher Program (CFDA#14.871) Material Non-Compliance Material Weakness in Internal Control over Compliance Tenant files for the Housing Choice Voucher Program are materially incomplete. Criteria Entities receiving Federal Funds under the Uniform Guidance are required to comply with certain conditions of the grant agreement and are required to have in place an internal control system that reasonably assures compliance with the requirement for Federal Awards such as Housing Choice Vouchers under 24 CFR Section 982.1. Cause During inspection of forty Housing Choice Voucher program files, we noted the following exceptions. • two files did not contain the 214 forms. • two files did not include documentation for EIV. • two files did not include a signed HUD Form 9886 • one file did not contain the participants birth certificate Effect of Condition The Authority is not in compliance with certain regulations regarding the Housing Choice Voucher Program under 24 CFR Section 982.1. Recommendation We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with 2 CFR-200. Questioned Costs: $0 Response: The following steps have been and are being taken regarding tenant certifications: 1. We issued a Request for Proposals for a third-party Contractor to perform all recertifications. We intend to award this Contract in July 2025. 2. All Managers and assistant Managers will use the third-party Contractor to learn proper recertification and documentation procedures.

Low Rent Public Housing (CFDA#14.850) Type of Deficiency: Material Weakness Compliance Requirement: Eligibility and Special Tests We selected forty files for the Low Rent Public Housing Program. 12 of the files were missing required documentation from EIV, 9866 forms, birth certificates and one the entire recertification for the year sampled was missing Cause: The Authority did not implement the proper controls to ensure that all tenants are properly recertified each year. Condition: The Authority did not follow the compliance requirements of 24CFR sections 5.230, 5.609 and 960.259. This was condition was noted as a finding the prior year audit report. Effect of Condition: The effect of not complying with the requirements in the Compliance Supplement may result in ineligible individuals being admitted to the program and improper rent calculations. Recommendation: We recommend that the Authority adopt controls and procedures to ensure compliance with the requirements of the Low Rent Public Housing Program. Questioned Costs -$0- Response: The following steps have been and are being taken regarding tenant certifications: 1. Staff has attended HOTMA training: An In-Depth Review of Programmatic Changes on 5/21/24 2. A new position was created at the Authority. Our most senior Manager is now our dedicated Quality Control Specialist and will be responsible for reviewing 100% of our files yearly.

Finding 2023-2 Housing Choice Voucher Program (CFDA#14.871) Material Non-Compliance Material Weakness in Internal Control over Compliance Tenant files for the Housing Choice Voucher Program are materially incomplete. Criteria Entities receiving Federal Funds under the Uniform Guidance are required to comply with certain conditions of the grant agreement and are required to have in place an internal control system that reasonably assures compliance with the requirement for Federal Awards such as Housing Choice Vouchers under 24 CFR Section 982.1. Cause During inspection of twelve Housing Choice Voucher program files, we noted the following exceptions. • One file was missing the 50058 form. • Four files did not include documentation for EIV. • Seventeen files did not include a signed HUD Form 9886 Effect of Condition The Authority is not in compliance with certain regulations regarding the Housing Choice Voucher Program under 24 CFR Section 982.1. Recommendation We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with 2 CFR-200. Questioned Costs: $0 Response: The following steps have been and are being taken regarding tenant certifications: 1. Staff has attended HOTMA training: An In-Depth Review of Programmatic Changes on 5/21/24 2. A new position was created at the Authority. Our most senior Manager is now our dedicated Quality Control Specialist and will be responsible for reviewing 100% of our files yearly. Finding 2023-2 Housing Choice Voucher Program (CFDA#14.871) Material Non-Compliance Material Weakness in Internal Control over Compliance Tenant files for the Housing Choice Voucher Program are materially incomplete. Criteria Entities receiving Federal Funds under the Uniform Guidance are required to comply with certain conditions of the grant agreement and are required to have in place an internal control system that reasonably assures compliance with the requirement for Federal Awards such as Housing Choice Vouchers under 24 CFR Section 982.1. Cause During inspection of twelve Housing Choice Voucher program files, we noted the following exceptions. • One file was missing the 50058 form. • Four files did not include documentation for EIV. • Seventeen files did not include a signed HUD Form 9886 Effect of Condition The Authority is not in compliance with certain regulations regarding the Housing Choice Voucher Program under 24 CFR Section 982.1. Recommendation We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with 2 CFR-200. Questioned Costs: $0 Response: The following steps have been and are being taken regarding tenant certifications: 1. Staff has attended HOTMA training: An In-Depth Review of Programmatic Changes on 5/21/24 2. A new position was created at the Authority. Our most senior Manager is now our dedicated Quality Control Specialist and will be responsible for reviewing 100% of our files yearly. Finding 2023-2 Housing Choice Voucher Program (CFDA#14.871) Material Non-Compliance Material Weakness in Internal Control over Compliance Tenant files for the Housing Choice Voucher Program are materially incomplete. Criteria Entities receiving Federal Funds under the Uniform Guidance are required to comply with certain conditions of the grant agreement and are required to have in place an internal control system that reasonably assures compliance with the requirement for Federal Awards such as Housing Choice Vouchers under 24 CFR Section 982.1. Cause During inspection of twelve Housing Choice Voucher program files, we noted the following exceptions. • One file was missing the 50058 form. • Four files did not include documentation for EIV. • Seventeen files did not include a signed HUD Form 9886 Effect of Condition The Authority is not in compliance with certain regulations regarding the Housing Choice Voucher Program under 24 CFR Section 982.1. Recommendation We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with 2 CFR-200. Questioned Costs: $0 Response: The following steps have been and are being taken regarding tenant certifications: 1. Staff has attended HOTMA training: An In-Depth Review of Programmatic Changes on 5/21/24 2. A new position was created at the Authority. Our most senior Manager is now our dedicated Quality Control Specialist and will be responsible for reviewing 100% of our files yearly.

Finding 2022-001 Low Rent Public Housing (CFDA#14.850) Type of Deficiency: Material Weakness Compliance Requirement: Eligibility and Special Tests We selected forty files for the Low Rent Public Housing Program. 10 of the files were missing the EIV, and two were not recertified, 2 had no 9886 form, 2 had no evidence of choice of flat rent given and 1 had no 50058 form. Cause: The Authority did not implement the proper controls to ensure that all tenants are properly recertified each year. Condition: The Authority did not follow the compliance requirements of 24CFR sections 5.230, 5.609 and 960.259. This was condition was noted as a finding the prior year audit report. Effect of Condition: The effect of not complying with the requirements in the Compliance Supplement may result in ineligible individuals being admitted to the program and improper rent calculations. Recommendation: We recommend that the Authority adopt controls and procedures to ensure compliance with the requirements of the Low Rent Public Housing Program. Questioned Costs -$0- Response: The following steps have been and are being taken regarding tenant certifications: 1. After contracting a third-party entity to review 10% of our files in Oct 2022, the findings of said review led to the recommendation to retrain staff. 2. All Managers and assistant Managers received HCV & PH Rent Calculation Training In June 2023. 3. We are also currently working with our TA from HUD, Ms. Valerie Jackson. Ms. Jackson has identified and is about to roll out training for our staff, to uniform and streamline our tenant files.

Finding 2022-2 Housing Choice Voucher Program (CFDA#14.871) Material Non-Compliance Material Weakness in Internal Control over Compliance Tenant files for the Housing Choice Voucher Program are materially incomplete. Criteria Entities receiving Federal Funds under the Uniform Guidance are required to comply with certain conditions of the grant agreement and are required to have in place an internal control system that reasonably assures compliance with the requirement for Federal Awards such as Housing Choice Vouchers under 24 CFR Section 982.1. Cause During inspection of twelve Housing Choice Voucher program files, we noted the following exceptions. ? Two files were not recertified. ? One file did not include documentation for EIV. ? Three files HAP payment did not agree to the HAP register. ? Two files did not include HUD Form 9886 Effect of Condition The Authority is not in compliance with certain regulations regarding the Housing Choice Voucher Program under 24 CFR Section 982.1. Recommendation We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with 2 CFR-200. Questioned Costs: $0 Response The following steps have been and are being taken regarding tenant certifications: 1. After contracting a third-party entity to review 10% of our files in Oct 2022, the findings of said review led to the recommendation to retrain staff. 2. All Managers and assistant Managers received HCV & PH Rent Calculation Training In June 2023. 3. We are also currently working with our TA from HUD, Ms. Valerie Jackson. Ms. Jackson has identified and is about to roll out training for our staff, to uniform and streamline our tenant files.

Finding 2021-001 Low Rent Public Housing (CFDA#14.850) Type of Deficiency: Material Weakness Compliance Requirement: Eligibility and Special Tests We selected forty files for the Low Rent Public Housing Program, One file was missing the EIV and two files were missing the signed rent addendum. Cause: The Authority did not implement the proper controls to ensure that all tenants are properly recertified each year. Condition: The Authority did not follow the compliance requirements of 24CFR sections 5.230, 5.609 and 960.259. This was condition was noted as a finding the prior year audit report. Effect of Condition: The effect of not complying with the requirements in the Compliance Supplement may result in ineligible individuals being admitted to the program and improper rent calculations Recommendation: We recommend that the Authority adopt controls and procedures to ensure compliance with the requirements of the Low Rent Public Housing Program. Questioned Costs -$0- Response: The following steps have been and are being taken regarding tenant certifications: 1. Starting December 1st 2020, a file quality control procedure has been implemented in which five random files are reviewed per AMP by our Director of Management each month. 2. HHA has bolstered our AMP based sites by reorganizing Staff to give Site Managers more assistance in performing annual re-certifications correctly.

Finding 2020-001 Low Rent Public Housing (CFDA#14.850) Type of Deficiency: Material Weakness Compliance Requirement: Eligibility and Special Tests We selected forty files for the Low Rent Public Housing Program. One of the files selected could not be produced by the Authority, one file contained only the 50058 and EIV, one file contained only the 50058 form and one file was missing the EIV form and two did not contain any evidence of recertification. Cause: The Authority did not implement the proper controls to ensure that all tenants are properly recertified each year. Condition: The Authority did not follow the compliance requirements of 24CFR sections 5.230, 5.609 and 960.259. This was condition was noted as a finding the prior year audit report. Effect of Condition: The effect of not complying with the requirements in the Compliance Supplement may result in ineligible individuals being admitted to the program and improper rent calculations Recommendation: We recommend that the Authority adopt controls and procedures to ensure compliance with the requirements of the Low Rent Public Housing Program. Questioned Costs -$0- Response: The following steps have been and are being taken regarding tenant certifications: 1. Starting December 1st 2020, a file quality control procedure has been implemented in which five random files are reviewed per AMP by our Director of Management each month. 2. HHA has bolstered our AMP based sites by reorganizing Staff to give Site Managers more assistance in performing annual re-certifications correctly

Finding 2019-1 Low Rent Public Housing (CFDA#14.850) Type of Deficiency: Material Weakness Compliance Requirement: Eligibility and Special Tests We selected forty files for the Low Rent Public Housing Program. Fifteen of the files did not contain third party verification of income through the EIV system as required. Cause: The Authority did not implement the proper controls to ensure that all tenants are properly recertified each year. Condition: The Authority did not follow the compliance requirements of 24CFR sections 5.230, 5.609 and 960.259. This was condition was noted as a finding the prior year audit report. Effect of Condition: The effect of not complying with the requirements in the Compliance Supplement may result in ineligible individuals being admitted to the program and improper rent calculations Recommendation: We recommend that the Authority adopt controls and procedures to ensure compliance with the requirements of the Low Rent Public Housing Program. Questioned Costs -$0- Response: Starting July 1st 2019, a file quality control procedure has been implemented in which five random files are reviewed per AMP by our Director of Management each month. HHA has bolstered our AMP based sites by reorganizing Staff to give Site Managers more assistance in performing annual re-certifications correctly. HHA has set aside funds for a two-step revamping of our tenant file systems during the summer/fall of 2019. Phase One of this project will bring an independent consultant in to HHA to perform a thorough sampling of our files, rewrite our certification procedures, and hold staff training in our new system. Phase Two of the project will be the bringing in of temporary clerical workers to go through all of HHA?s tenant files to re-organize, cull, and bring those files up to date. We anticipate that the entire project will be completed by December of 2019. It is acknowledged that this may not completely eradicate this finding during the 2019 Fiscal Year, but will be fully effective during the 2020 Fiscal Year.

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