Housing Authority of the County of CumberlandLocal Government

The PHA must inspect the unit leased to a family at least bi-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 §§982.405, 983.103)). Additionally, 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. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). During our audit, we identified two (2) failed HQS with life-threating fails that did not receive a pass within the required 24-hour time frame. The HQS population had 135 failed inspections. We selected a sample of 15 inspection and identified of those 15 reviewed 2 did not obtain a re-inspection pass within the Criteria noted above and no rent abatement process was enforced on landlord. Recommendations We suggest the Authority properly oversee compliance with regulations and enforce rent abatements if necessary to adherence to federal compliance requirements. Corrective Action Plan Staff have implemented a new approach to addressing compliance issues immediately and notifying the Deputy Executive Director to enforce abatements. Staff are also required to do additional annual training.

2023-003

In accordance with the 2014 Appropriations Act Section 242, the utility allowance for a family shall be the lower of: (1) the utility allowance amount for the family unit size; or (2) the utility allowance amount for the unit size of the unit rented by the family. However, upon the request of a family that includes a person with disabilities, the PHA must approve a utility allowance higher than the applicable amount if such a higher utility allowance is needed as a reasonable accommodation in accordance with HUD's regulations in 24 CFR part 8 to make the program accessible to and usable by the family member with a disability. This provision applies only to vouchers issued after the effective date of this notice (June 12, 2014) and to current program participants. For current program participants, a PHA must implement the new allowance at the family's next annual reexamination, provided that the PHA is able to provide a family with at least 60 days' notice prior to the reexamination. During the audit, we noted two (2) HUD Forms 50058 had utility allowances calculated not in accordance with the above criteria. The Authority had roughly 120 vouchers issued throughout the fiscal year under examination which would translate to 1,400 Housing Assistance Payment transactions for the year. Of these we reviewed 40 individual Housing Assistance Payment transactions and found 2 instances of noncompliance. Recommendation We recommend that Management implement procedures to ensure compliance with the above regulations as it relates to the Section 8 Housing Choice Voucher Program. Corrective Action Plan File audits are being done quarterly beyond regularly quality control audits. Staff are required to do additional annual compliance training to ensure procedures are being followed.

Criteria: Financial Data Schedule (FDS) submission for unaudited financials are due within 2 months after the fiscal year end; FDS audited submissions are due 9 months after fiscal year end; and the Federal Audit Clearing House reporting package is due 30 days after receipt of the auditors reports or 9 months after the end of the fiscal year (24 CFR section 5.801). Condition: Management missed deadlines for the audited submissions and missed the deadline for completing the Federal Audit Clearing House reporting package. Context: Significant delay in the audit process resulted from these journal entries identified in finding 2023-001. Cause: Management was late in submitting its financial information to the auditor. This in part was caused by personnel changes that limited its ability to produce timely and reliable financial data. Effect: The Authority will receive a lower SEMAP score and will be classified as a troubled housing authority which could impact its subsidies. Recommendations: The Authority needs to improve its internal controls over financial reporting by submitting its financial data on a timelier basis. Views of responsible officials and planned corrective action: : The Authority agrees with this finding and has outlined a plan of action to address Audit Finding 2023-002. The Authority has implemented several activities that are designed to fully address the finding and prevent any reoccurrence in the future. These actions include: An Assistant Finance Director and a new Staff Accountant have been hired to ensure timely preparation of financial statements. New financial software has been implemented along with a new chart of accounts that provides for more consistent reporting and year end close. The process of internal reporting will be monitored to ensure timely submission of financial reports.

Criteria: The PHA must inspect the unit leased to a family at least bi-annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control reinspections. The PHA must prepare a unit inspection report (24 CFR §§982.405, 983.103)). Additionally, 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. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family‐caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: During our audit, we identified four (4) failed HQS that did not receive a pass for several months and no rent abetment process was started or enforced during that time period. Context: The HQS population was 135 failed inspection. We selected a sample of 29 inspection and identified of those 29 reviewed 4 did not obtain a re-inspection pass within the Criteria noted above and no rent abetment process was enforce on landlord. Cause: The Authority staff did not want to jeopardize the tenants lease by enforcing the rent abatements and rather worked with the landlord over an extend period to resolve the failed inspection issues. Effect: The Authority is non‐compliant with the federal regulations over this federal program, this could potentially result in operating and financial penalties. Recommendations: The Authority will partner with nonprofit and other county agencies to ensure, in cases where landlords have failed inspections, any negative impact to tenants will be minimized. The Authority will enforce their policies related to inspections with respect to all landlords and tenants. Sincerely yours, Kira Kessler Finance Director

The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal Award Program Audit Finding 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing 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 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 199 units. Of a sample size of twelve (12) tenant files, the following was noted: • Declaration of Section 214 Statuses form was missing in 2 files Our sample size is statistically valid. Known Questioned Costs: $8,912 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 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 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. Yolanda Hart, Public Housing Property Manager, will be responsible to implement this corrective action by June 30, 2023. If the U.S. Department of Housing and Urban Development has any questions regarding this plan, please call Mary Kuna, Executive Director, at 717-249-0789 ext. 118.

HOUSING AUTHORITY OF CUMBERLAND COUNTY 114 N Hanover Street Carlisle, PA 17013 Phone: (717) 249-0789 Corrective Action Plan For the year ended June 30, 2019 U.S. Department of Housing and Urban Development: The Housing Authority of Cumberland County respectfully submits the following corrective action plan for the year ended June 30, 2019. Auditor: Novogradac and Company, LLP Certified Public Accountants 1433 Hooper Avenue Suite 329 Toms River, New Jersey 08753 The findings from the June 30, 2019 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings- Financial Statement Audit There were no findings related to the financial statements which are required to be reported in accordance with government auditing standards generally accepted in the United States of America. Federal Award Findings and Questioned Costs Finding 2019-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Continuum of Care Program Federal Catalog Numbers: 14.267 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 (Continuum of Care 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 578.77, 5.609, and 5.611). In addition, the Authority must examine a program participant's income initially, and at least annually thereafter, to determine the amount of the contribution toward rent payable by the program participant. Adjustments to a program participant's contribution toward the rental payment must be made as changes in income are identified. 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 100 units. Of a sample size of 10 tenant files, the following was noted: - Verification of income was missing in 5 files - Verification of assets was missing in 1 file - Annual calculation of rent was missing in 1 file Our sample size is statistically valid. Known Questioned Costs: $48,745 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to verification of income and assets, and calculating rent. 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 Continuum of Care Program is in material non-compliance with the eligibility type of compliance related to verification of income and assets, and calculating rent. 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 has recognized the deficiencies in the Continuum of Care Program and has increased oversight from the Executive Director. Timothy F. Whelan is responsible to remedy the deficiency by June 30, 2020. Schedule of Prior Year Audit Findings None reported.