HOUSING AUTHORITY OF THE CITY OF MILLEDGEVILLE

Finding 2021-001 ? Special Tests and Provisions ? Davis Bacon ? Repeat Finding Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects ? CFDA 14.155; Grant period ? year ended September 30, 2021 Criteria: HUD Handbook 1344.1 and the Code of Federal Regulations provide the applicable requirements federally assisted construction contracts must follow with respect to the administration over Procurement and Davis Bacon Act compliance. Specifically, entities receiving federal assistance through grants, loans and loan guarantees are required to verify that all prime contractors are eligible prior to awarding the contract. Additionally, non-federal entities shall include in their construction contracts, subject to the Davis-Bacon Act, a requirement that the contractor or subcontractor comply with the requirements of the Davis-Bacon Act. This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6). Entities should also be interviewing the contractor or subcontractor?s employees to substantiate the accuracy of the certified payrolls. Condition & Cause: The Authority was unable to provide certified payroll for each week in which work was performed on the renovation contract. Effect or Potential Effect: Potential noncompliance with Davis-Bacon if workers are not being paid prevailing wage rates. Questioned Costs ? None Identified Recommendation: We recommend that the Authority put procedures in place to ensure that the weekly certified payrolls are maintained on all contracts.

Finding 2020-001 ? Tenant Files ? Eligibility ? EIV Reporting Section 8 Housing Assistance Payments ? CFDA 14.195; Grant period ? year ended September 30, 2020 Criteria: The Uniform Financial Reporting Standards (24 CFR section 5.233) mandate the use of HUD's Enterprise Income Verification (EIV) System. The EIV system is a web-based application which provides owners with employment, wage, unemployment compensation and Social Security benefit information for tenants participating in HUD's assisted housing programs. Condition & Cause: The Authority did not use the EIV System to verify employment and income. The Authority has experienced several changes in management which delayed the use of the EIV System. Effect or Potential Effect: Potential administrative and subsidy payment errors due to noncompliance with HUD administrative guidance. Questioned Costs ? None Identified Recommendation: We recommend that the Authority put procedures in place to ensure that the mandated use of the EIV System is followed in accordance with the Uniform Financial Reporting Standards. Reply: John Corcoran, Interim Executive Director, expects the deficiencies which led to this finding to be resolved and this finding to be cleared in subsequent year as the Authority implemented the EIV System subsequent to year-end.

Finding 2020-002 ? Special Tests and Provisions ? Move Out List Section 8 Housing Assistance Payments ? CFDA 14.195; Grant period ? year ended September 30, 2020 Criteria: The owner must reduce claims for assistance on vacant units under certain circumstances. However, there are instances where special claims are allowed for vacancy loss, unpaid rent, and tenant damages on eligible units (24 CFR sections 880.611, 881.601, 882.411, 882.808(f), 883.701, 884.106, 886.109, and 886.309). Condition & Cause: Tenants were not accurately removed from the subsequent month?s occupancy report after vacating the unit. The Authority has experienced several changes in management and the vacancies were not reported in the subsequent month?s occupancy. Effect or Potential Effect: Potential assistance payments inappropriately paid to the owner for vacant units. Questioned Costs: $7,131 Recommendation: We recommend that the Authority put procedures in place to ensure that the move-outs are reported in the subsequent month of the move-out. Reply: John Corcoran, Interim Executive Director, expects the deficiencies which led to this finding to be resolved and this finding to be cleared in subsequent year.

Finding 2020-003 ? Special Tests and Provisions ? Davis Bacon Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects ? CFDA 14.155; Grant period ? year ended September 30, 2020 Criteria: HUD Handbook 1344.1 and the Code of Federal Regulations provide the applicable requirements federally assisted construction contracts must follow with respect to the administration over Procurement and Davis Bacon Act compliance. Specifically, entities receiving federal assistance through grants, loans and loan guarantees are required to verify that all prime contractors are eligible prior to awarding the contract. Additionally, non-federal entities shall include in their construction contracts, subject to the Davis-Bacon Act, a requirement that the contractor or subcontractor comply with the requirements of the Davis-Bacon Act. This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6). Entities should also be interviewing the contractor or subcontractor?s employees to substantiate the accuracy of the certified payrolls. Condition & Cause: The Authority was unable to provide certified payroll for each week in which work was performed on the renovation contract. Effect or Potential Effect: Potential noncompliance with Davis-Bacon if workers are not being paid prevailing wage rates. Questioned Costs ? None Identified Recommendation: We recommend that the Authority put procedures in place to ensure that the weekly certified payrolls are maintained on all contracts. Reply: John Corcoran, Interim Executive Director, expects the deficiencies which led to this finding to be resolved and this finding to be cleared in subsequent year.

Finding 2019-001 ? Reporting ? Section 3 Summary ReportingLow Rent Public Housing ? CFDA 14.850; Grant period ? year ended September 30, 2019Criteria:In accordance with 24 CFR Part 135.90 information for Section 3 Summary report Form, HUD 60002, must be entered using the Section 3 Performance Evaluation and Registry System (SPEARS) no later than sixty days after the recipient?s year end.Condition & Cause:The Authority did not submit the required HUD 60002 within sixty days of its year end.Effect or Potential Effect: The Authority is not in compliance with requirements for the Low Income Public Housing Program.Questioned Costs ? None IdentifiedPerspective Information:Due to changes in management the Section 3 Summary report was not filed timely for 2019.Recommendation:We recommend the Authority establish internal controls for Section 3 summary reporting to ensure thereports are submitted on a timely basis for future years. Reply:The Authority established controls over the Section 3 Summary reporting to ensure the report is filed timely. The controls were put in place after the due date of the Section 3 Summary report for 2019. John Corcoran, Interim Executive Director, expects the deficiencies which led to this finding to be cleared in fiscal year 2020. The 2020 Section 3 Summary report was filed timely.

Finding 2019-002 ? Tenant Files ? Eligibility ? EIV ReportingLow Rent Public Housing ? CFDA 14.195; Grant period ? year ended September 30, 2019Criteria:The Uniform Financial Reporting Standards (24 CFR section 5.233) mandate the use of HUD's Enterprise Income Verification (EIV) System. The EIV system is a web-based application which provides owners with employment, wage, unemployment compensation and Social Security benefit information for tenants participating in HUD's assisted housing programs.Condition & Cause:The Corporation did not use the EIV System to verify employment and income. The Corporation has experienced several changes in management which delayed the use of the EIV System.Effect or Potential Effect: Potential administrative and subsidy payment errors due to noncompliance with HUD administrative guidance.Questioned Costs ? None IdentifiedRecommendation:We recommend that the Corporation put procedures in place to ensure that the mandated use of the EIV System is followed in accordance with the Uniform Financial Reporting Standards.Reply:John Corcoran, Interim Executive Director, expects the deficiencies which led to this finding to be resolved and this finding to be cleared in subsequent year as the Corporation started using the EIV System subsequent to year-end.

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