Housing Authority of Racine County

2024 – 001: Income and Asset Verification Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Federal Award Identification Number and Year: WI183VO- 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: For both family income examinations and reexaminations, obtain and document in the family file third party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent (24 CFR 985.516). Determine income eligibility and calculate the tenant’s rent payment using the documentation from third party verification in accordance with 24 CFR Part 5 Subpart F (24 CFR section 5.601 et seq.) (24 CFR sections 982.201, 982.515, and 982.516). Condition: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: None Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not maintain evidence of completion of income verification as a part of the annual re-examination, three (3) tenant files had clerical errors of the income calculation reported on the HUD 50058, and one (1) tenant files did not contain third party verification of assets. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 985.516. Repeat Finding: Yes; 2023-003 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2024 – 002: Reasonable Rent Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Federal Award Identification Number and Year: WI183VO- 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA 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 PHS must maintain records to document the bases 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: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: None Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not include documentation of performance of rent reasonableness prior to the lease date. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: 2023-004 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2024 – 003: Utility Allowance Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Federal Award Identification Number and Year: WI183VO- 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised. Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: None Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not include proper documentation of utility allowance. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: 2023-005 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2024 – 004: Housing Quality Standards (HQS) Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Federal Award Identification Number and Year: WI183VO- 2024 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (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 testing, we noted the Authority failed to comply with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: None Context: From a sample of thirty-four (34) program participant files selected for testing, we noted two (2) instances where the repairs were not completed within 30 days and three (3) instances where life threating repairs were not completed within 24 HRs in accordance with the stated criteria and the HAP was not held. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2023-007 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 002: Segregation of Duties - Compliance Federal agency: All Programs Federal program title: All Programs Assistance Listing No.: All Programs Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance Criteria or specific requirement: It is the Authority’s responsibility to establish and maintain systems of internal control over compliance that includes proper segregation of duties. Condition: The Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance to an appropriately low level. Context: While performing audit procedures, it was noted that the Authority does not have a system of internal controls over compliance built into the Authority’s policies and procedures that appropriately reduces the risk of noncompliance with respect to compliance requirements related to eligibility and special tests and provisions. Cause: The Authority has not taken the appropriate steps to construct internal controls within their policies and procedures related to compliance with the Federal programs to the extent that the risk of noncompliance is reduced to an appropriately low level. Effect: As a result of the lack of segregation of duties and internal control, there were several compliance findings noted that resulted in material noncompliance with respect to eligibility and special tests and provisions. Repeat Finding: Yes; 2022-002. Recommendation: We recommend that the Authority’s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 003: Income and Asset Verification Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: Income reported on the tenant assistance application was verified by the housing specialist by obtaining 3rd party verification of annual income. (3rd party verification includes direct confirmation from an employer, at least 4 paystubs, EIV report (required for 10/09 and later), SS award letter, printouts from Dept of Social Services for TANF, child support, etc.) (24 CFR 985.516). Assets reported on the tenant assistance application were verified by the leasing specialist by obtaining 3rd party verification of assets. If the tenant listed bank accounts, the PHA must obtain account balances from the bank or copies of bank statements. If the tenant receives SS income or wages, look at these forms to see if there is any indication of direct deposit. If so, the PHA should have gotten bank statements). (24 CFR 985.516). HAP/TAP was properly calculated using all verified information from above and was inputted into the HUD 50058 calculation. If the income reported is not correct per #2 above or there was no 3rd party verification of assets, this is incorrect as well. Condition: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: Known - Unknown | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not maintain evidence of completion of income verification as a part of the annual re-examination and six (6) tenant files did not contain third party verification of assets. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 985.516. Repeat Finding: Yes; 2022-003 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 004: Reasonable Rent Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA 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 PHS must maintain records to document the bases 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: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, five (5) tenant files did not include documentation of performance of rent reasonableness prior to the lease date. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 005: Utility Allowance Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised. Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not include proper documentation of utility allowance. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 006: Annual Inspections Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 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)). Condition: During our testing, we noted the Authority failed to comply with the requirements of the annual HQS inspection as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-005 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 007: Housing Quality Standards (HQS) Enforcement Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (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 testing, we noted the Authority failed to comply with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: From a sample of twenty one (21) program participant files selected for testing, two (2) instances noted where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2022-006 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 008: Financial Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2023 – December 31, 2023 Type of Finding: • Internal Control, Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The PHA is required to submit an unaudited Financial Information within 2 months and audited annual Financial Report within 9 months to HUD electronically via the FASS-PH system. Condition: During our testing, we noted the Authority failed to comply with the requirements of the financial reporting as stated in the criteria section of this finding. Questioned Costs: Known - None | Likely - Undeterminable Context: Unaudited REAC was submitted after the required two-month deadline. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 002: Segregation of Duties - Compliance Federal agency: All Programs Federal program title: All Programs Assistance Listing No.: All Programs Award period: January 1, 2022 ? December 31, 2022 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance Criteria or specific requirement: It is the Authority?s responsibility to establish and maintain systems of internal control over compliance that includes proper segregation of duties. Condition: The Authority does not have a system of internal controls over compliance built into the Authority?s policies and procedures that appropriately reduces the risk of noncompliance to an appropriately low level. Context: While performing audit procedures, it was noted that the Authority does not have a system of internal controls over compliance built into the Authority?s policies and procedures that appropriately reduces the risk of noncompliance with respect to compliance requirements related to eligibility and special tests and provisions. Cause: The Authority has not taken the appropriate steps to construct internal controls within their policies and procedures related to compliance with the Federal programs to the extent that the risk of noncompliance is reduced to an appropriately low level. Effect: As a result of the lack of segregation of duties and internal control, there were several compliance findings noted that resulted in material noncompliance with respect to eligibility and special tests and provisions. Repeat Finding: Yes; 2021-003. Recommendation: We recommend that the Authority?s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 003: Income and Asset Verification Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2022 ? December 31, 2022 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance ? Material Noncompliance Criteria or specific requirement: Income reported on the tenant assistance application was verified by the housing specialist by obtaining 3rd party verification of annual income. (3rd party verification includes direct confirmation from an employer, at least 4 paystubs, EIV report (required for 10/09 and later), SS award letter, printouts from Dept of Social Services for TANF, child support, etc.) (24 CFR 985.516). Assets reported on the tenant assistance application were verified by the leasing specialist by obtaining 3rd party verification of assets. If the tenant listed bank accounts, the PHA must obtain account balances from the bank or copies of bank statements. If the tenant receives SS income or wages, look at these forms to see if there is any indication of direct deposit. If so, the PHA should have gotten bank statements). (24 CFR 985.516). HAP/TAP was properly calculated using all verified information from above and was inputted into the HUD 50058 calculation. If the income reported is not correct per #2 above or there was no 3rd party verification of assets, this is incorrect as well. Condition: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: Known - Unknow Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, four (4) tenant files did not contain an updated EIV form as a part of the annual re-examination and five (5) tenant files did not contain third party verification of assets. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 985.516. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 004: Maintenance of Release Forms Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2021 ? December 31, 2021 Type of Finding: ? Internal Control, Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) tenant files did not contain the required release of information form signed by the tenant. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: Yes; 2021-007 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 005: Annual Inspections Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2022 ? December 31, 2022 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance ? Material Noncompliance Criteria or specific requirement: Reviewed the tenant file to ensure that it documented the completion of an HQS inspection in accordance with the HCVP Admin Plan and 24 CFR 982.158(d) & 982.405(b) either on a paper inspection form or electronically. This includes the proper reinspection procedures. If the family was a participant in the Family Self Sufficiency (FSS) Program an inspection is not required. (Special Tests and Provisions- Housing Quality Standards Inspections). Per discussion with Roscely Santiago, there were no annual HQS Inspections performed in 2021. Instead, HARC sent a letter acquiring signature of landlord and tenant that there were no life threatening deficiencies. The most recent passed inspection occurred within 12 months of previous passed inspection. If HQS required reinspections, re-inspection was completed with required time period. Condition: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: Known - None Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, twenty-one (21) tenant files failed their annual inspection, repairs were not completed within the required timeframe and HAP was not abated. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 006: Housing Quality Standards (HQS) Enforcement Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Number: 14.871, 14.879 Award period: January 1, 2022 ? December 31, 2022 Type of Finding: ? Internal Control, Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (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: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the criteria section of this finding. Questioned Costs: Known - None Likely - Undeterminable Context: From a sample of forty (40) program participant files selected for testing, we noted six (6) instances where the repairs were not completed timely in accordance with the stated criteria and the HAP was not held. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 982.158(d) and 982.404 related to the HQS enforcement. Repeat Finding: Yes; 2021-004 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of HQS enforcement. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 003: Segregation of Duties - Compliance Federal agency: All Programs Federal program title: All Programs Assistance Listing No.: All Programs Award period: January 1, 2021 ? December 31, 2021 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance Criteria or specific requirement: It is the Authority?s responsibility to establish and maintain systems of internal control over compliance that includes proper segregation of duties. Condition: The Authority does not have a system of internal controls over compliance built into the Authority?s policies and procedures that appropriately reduces the risk of noncompliance to an appropriately low level. Context: While performing audit procedures, it was noted that the Authority does not have a system of internal controls over compliance built into the Authority?s policies and procedures that appropriately reduces the risk of noncompliance with respect to compliance requirements related to eligibility and special tests and provisions. Cause: The Authority has not taken the appropriate steps to construct internal controls within their policies and procedures related to compliance with the Federal programs to the extent that the risk of noncompliance is reduced to an appropriately low level. Effect: As a result of the lack of segregation of duties and internal control, there were several compliance findings noted that resulted in material noncompliance with respect to eligibility and special tests and provisions. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2020-003. Recommendation: We recommend that the Authority?s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director, On-going

2021 ? 004: Housing Quality Standards (HQS) Enforcement Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Special Tests and Provisions Award period: January 1, 2021 ? December 31, 2021 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance ? Material Noncompliance Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (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 testing, we noted the Authority failed to comply with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: Known - Unknown Likely - Undeterminable Context: From a sample of twelve (12) program participant files selected for testing, four (4) tenant files noted life threatening deficiencies and four (4) files noted other deficiencies for which the reinspection and conclusion was not performed in accordance with the stated criteria. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 982.158(d) and 982.404 related to the HQS enforcement. Repeat Finding: Yes; 2020-004 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of HQS enforcement. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director, On-going

2021 ? 005: Utility Allowance Schedule Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Special Tests and Provisions Award period: January 1, 2021 ? December 31, 2021 Type of Finding: ? Internal Control, Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The PHA must maintain an up-to-date utility allowance schedule. The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised (24 CFR section 982.517). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements of the utility allowance schedule as stated in the criteria section of this finding. Questioned Costs: Known - None Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) files had inconsistencies between what is noted to be paid on the Form 50058 and the Utility Allowance Form. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the (24 CFR section 982.517) related to the utility allowance schedule. Repeat Finding: Yes; 2020-006 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the utility allowance schedule. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director, On-going

2021 ? 006: Rent Reasonableness Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Special Tests and Provisions Award period: January 1, 2021 ? December 31, 2021 Type of Finding: ? Internal Control, Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The PHA must determine that the rent to owner is reasonable at the time of initial leasing. Also, the PHA 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 PHS must maintain records to document the bases 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: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements of rent reasonableness schedule as stated in the criteria section of this finding. Questioned Costs: Known - None Likely - Undeterminable Context: From a sample of sixty (60) program participant files selected for testing, two (2) files did not include documentation of performance of rent reasonableness. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director, On-going

2021 ? 007: Maintenance of Release Forms Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Eligibility Award period: January 1, 2021 ? December 31, 2021 Type of Finding: ? Internal Control, Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of the household signs (a) one or more release forms to allow the PHA to obtain information from third parties; (b) a federally prescribed general release form for employment information; and (c) a privacy notice. Under some circumstances, other members of the family are required to sign these forms (24 CFR sections 5.212 and 5.230). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements as stated in the criteria section of this finding. Questioned Costs: Known - None Likely - Undeterminable Context: From a sample of forty (40) program participant files selected for testing, two (2) files did not the required releases in accordance with the stated criteria. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the stated criteria. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director, On-going

2020 ? 003: Segregation of Duties - Compliance Federal agency: All Programs Federal program title: All Programs Assistance Listing No.: All Programs Award period: January 1, 2020 ? December 31, 2020 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance Criteria or specific requirement: It is the Authority?s responsibility to establish and maintain systems of internal control over compliance that includes proper segregation of duties. Condition: The Authority does not have a system of internal controls over compliance built into the Authority?s policies and procedures that appropriately reduces the risk of noncompliance to an appropriately low level. Context: While performing audit procedures, it was noted that the Authority does not have a system of internal controls over compliance built into the Authority?s policies and procedures that appropriately reduces the risk of noncompliance with respect to compliance requirements related to eligibility and special tests and provisions. Cause: The Authority has not taken the appropriate steps to construct internal controls within their policies and procedures related to compliance with the Federal programs to the extent that the risk of noncompliance is reduced to an appropriately low level. Effect: As a result of the lack of segregation of duties and internal control, there were several compliance findings noted that resulted in material noncompliance with respect to eligibility and special tests and provisions. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2019-001. Recommendation: We recommend that the Authority?s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director (formerly Deputy Director), On-going

2020 ? 004: Housing Quality Standards (HQS) Enforcement Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Special Tests and Provisions Award period: January 1, 2020 ? December 31, 2020 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance ? Material Noncompliance Criteria or specific requirement: For units under HAP contract that fail to meet (Housing Quality Standards (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 testing, we noted the Authority failed to maintain documentation of compliance with the requirements of the HQS enforcement as stated in the criteria section of this finding. Questioned Costs: Known - $9,407 Likely - Undeterminable Context: From a sample of thirty-eight (38) program participant files selected for testing, five (5) files failed to maintain documentation of compliance with the requirements of HQS enforcement as stated in the criteria section of this finding. In each of the exceptions noted, the program participant file failed to document correction of HQS deficiencies identified during the initial HQS inspection. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the 24 CFR sections 982.158(d) and 982.404 related to the HQS enforcement. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of HQS enforcement. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director, On-going

Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Special Tests and Provisions Award period: January 1, 2020 ? December 31, 2020 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 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)). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements of the annual HQS inspection as stated in the criteria section of this finding. Questioned Costs: Known - None Likely - Undeterminable Context: From a sample of forty (40) program participant files selected for testing, three (3) files failed to maintain documentation of compliance with the requirements of annual HQS inspection reinspection requirements as stated in the criteria section of this finding. In each of the exceptions noted, the program participant file failed to document reinspection of HQS deficiencies identified during the initial HQS inspection. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. In addition, the Authority's administration plan requires that the Authority provide the landlord and tenant the result of the reinspection in writing as a component of internal control. From a sample of forty (40) program participant files selected for testing, eight (8) files failed to maintain the required letter to the landlord and tenant. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the (24 CFR sections 982.158(d) and 982.405(b)) related to the annual HQS inspection. Repeat Finding: 2019-003 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the annual HQS inspection. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director, On-going

Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Special Tests and Provisions Award period: January 1, 2020 ? December 31, 2020 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance ? Material Noncompliance Criteria or specific requirement: The PHA must maintain an up-to-date utility allowance schedule. The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised (24 CFR section 982.517). Condition: During our testing, we noted the Authority failed to maintain documentation of compliance with the requirements of the utility allowance schedule as stated in the criteria section of this finding. Questioned Costs: Known - None Likely - Undeterminable Context: From a sample of forty (40) program participant files selected for testing, thirteen (13) files failed to maintain documentation of compliance with the requirements of utility rate schedule as stated in the criteria section of this finding. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the (24 CFR section 982.517) related to the utility allowance schedule. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the utility allowance schedule. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director, On-going

Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Special Tests and Provisions Award period: January 1, 2020 ? December 31, 2020 Type of Finding: ? Internal Control, Material Weakness in Internal Control over Compliance ? Material Noncompliance Criteria or specific requirement: For both family income examinations and reexaminations, obtain and document in the family file third-party verification of (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income based rent (24 CFR section 982.516). Condition: During our testing, we noted the Authority failed to maintain documentation of eligibility with the requirements of the (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income based rent as stated in the criteria section of this finding. Questioned Costs: Known - None Likely - Undeterminable Context: From a sample of forty (40) program participant files selected for testing, five (5) files failed to maintain documentation of eligibility with the requirements of the (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income based rent as stated in the criteria section of this finding. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The Authority's system of internal controls included in the policies and procedures failed to identify the noncompliance as described in the condition section of this finding. Effect: The failure of the internal controls has resulted in noncompliance with the requirements of the (24 CFR section 982.516) related to the (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income based rent. Repeat Finding: No Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income based rent. Views of responsible officials: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director, On-going

2019 ? 001: Segregation of Duties Type of Finding: ? Internal Control, Significant Deficiency Criteria or specific requirement: It is the Authority?s responsibility to establish and maintain systems of internal control over financial reporting that includes proper segregation of duties. Condition: The Deputy Director has access rights to all accounting modules. These rights allow her to approve purchases and process vendor checks, enter time, approve payroll checks, and record, and reconcile cash receipts. The Authority has review procedures in place around these areas to mitigate the risk associated, however, ideally, these duties would be segregated. Context: While performing audit procedures, it was noted that management does not have internal controls in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Cause: Proper segregation of duties would separate the recording, review and reconciliation processes. The size of the Authority?s staff precludes a full segregation of duties over these activities. Effect: These rights result in a lack of segregation of duties. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2018-001. Recommendation: We recommend that the Authority?s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Views of responsible officials: The Executive Director will continue to closely supervise and review all accounting information in order to prevent or detect errors and irregularities. Responsible person and anticipated completion date: Deb Madsen, Executive Director (formerly Deputy Director), On-going

2019 ? 002: Housing Quality Standards Inspection Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Special Provision Award period: January 1, 2019 ? December 31, 2019 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: 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)). Condition: During our testing, we noted the Authority failed to maintain documentation of re-inspection in accordance with the above stated criteria. Questioned Costs: Known questioned costs of $18,828 were identified. Context: From a sample of forty (40) program participant files selected for testing, ten (10) files had documentation indicating that the inspected unit did not meet Housing Quality Standards and the HAP was suspended. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. The file indicated that the HAP resumed but did not contain evidence that HQS deficiencies were corrected. Cause: The Authority did not have controls in-place that ensured that the documentation of a re-inspection occurred prior to the HAP being resumed. The lack of documentation indicating successful completion of re-inspection could result in a HAP inadvertently being re-instated resulting in questioned costs. Effect: Ten (10) individual?s file did not maintain HQS re-inspection documentation in accordance with the above criteria. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2018-002. Recommendation: We recommend that Management review the process for maintenance of documentation to determine if there are any enhancements to the process that could prevent the future occurrence of missing documentation. Views of Responsible Official: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director (formerly Deputy Director), On-going

2019 ? 003: Eligibility Federal agency: Housing Choice Voucher Program Federal program title: U.S. Department of Housing and Urban Development CFDA Number: 14.871 Compliance requirement: Special Tests and Provisions Award period: January 1, 2019 ? December 31, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The PHA must perform an examination of a tenant's voucher at least annually to attain 3rd party verification of annual income, verification of tenant assets, and that HAP/TAP is properly calculated using all verified information aforementioned. Condition: During our testing, we noted the Authority failed to maintain documentation of the performance of an annual re-examination in accordance with the above stated criteria. Questioned Costs: $10,970 Context: From a sample of forty (40) program participant files selected for testing, one (1) file failed to maintain documentation of the performance of an annual re-examination. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Cause: The process and control to maintain the documentation of the performance of an annual re-examination at the time of the re-examination failed and the documentation of the re-examination was not maintained in the tenant file. Effect: Failure to complete the reasonable rent review could result in the Authority paying for housing choice vouchers tenants are not eligible to receive. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that Management implement a system of control that requires a review of the tenant intake file by an individual separate from the designated housing specialist. Views of Responsible Official: There is no disagreement with the audit finding. Responsible person and anticipated completion date: Deb Madsen, Executive Director (formerly Deputy Director), On-going

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