Palm Beach County Housing AuthorityLocal Government

Housing Voucher Cluster Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2025 Award Period: October 1, 2024 to September 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (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). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) 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). (3) 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). (4) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR section 982.516). Condition: During testing of 60 tenant files, eligibility-related exceptions were identified in 3 files. • In 1 instance, the Form HUD-50058 in effect during fiscal year 2025 per Yardi was dated 2022. No recertification for the tenant had been performed since. As a result, key recent eligibility elements, including household composition, income, assets, expenses, eligibility determinations, and the accuracy of the HAP calculation, could not be verified. • In 2 instances, HAP payments continued after tenants had vacated the assisted units and were no longer participating in the HCV program (end-of-participation dates of November 2023 and December 2023). The Authority was using old tenant data and was still paying HAP to the landlords in fiscal year 2025. For both households, the Authority initiated retroactive billing to recover HAP payments made after the tenant vacated; however, as of the date of testing, the funds had not been recovered from one landlord. Questioned Costs: $10,633 Context: Out of 60 tenant files tested, 3 tenant files contained errors as noted above. Cause: The Authority had inadequate monitoring controls over (1) timely updates and recertifications in the tenant file, including Form HUD-50058, and (2) the timely termination of HAP payments upon tenant move-out. Effect: Failure to maintain valid eligibility documentation and discontinue HAP payments timely increases the risk of: • Unsupported eligibility determinations and inaccurate HAP calculations • Improper payments to landlords for ineligible participants, resulting in potential questioned costs and noncompliance with HUD requirements. • Inaccurate and untimely information reported to HUD Repeat Finding: This is a repeat finding from previous years. The finding numbers were 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, 2022-001, 2023-001, and 2024-001. Recommendation: We recommend the Authority strengthen internal controls over tenant recertifications to ensure: • Form HUD-50058 and supporting eligibility documentation are current, complete, and properly maintained for all tenants • Timely processing of tenant move-outs and termination of HAP payments • Ongoing monitoring procedures to identify and promptly resolve instances of continued payments after program exit, including timely recovery of any overpayments Views of Responsible Officials: There is no disagreement with the audit finding.

HQS Enforcement Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2025 Award Period: October 1, 2024 to September 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: For units under HAP contract that fail to meet HQS, the Authority 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 Authority-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the Authority 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 Authority must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: During testing of 60 tenant files, HQS enforcement-related exceptions were identified in 1 file. • The Authority did not terminate the contract of 1 unit that failed to correct HQS deficiencies within the required timeframe. Questioned Costs: None. HAP was properly abated for this unit. Context: Out of 60 tenant files tested, 1 tenant file contained errors as noted above. Cause: The Authority had inadequate monitoring and enforcement controls over HQS follow-up procedures, including ensuring timely contract termination when required corrective actions are not completed timely. Effect: Failure to enforce HQS requirements increases the risk that: • Program participants occupy units that do not meet HUD housing quality standards, and • Improper HAP payments are made for noncompliant units, potentially resulting in questioned costs and noncompliance with HUD requirements. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Authority strengthen internal controls over HQS enforcement by implementing procedures to track and monitor HQS deficiencies and required correction timelines. Views of Responsible Officials: There is no disagreement with the audit finding.

Public Housing Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 2025 Award Period: October 1, 2024 to September 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (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 household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 960.259). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). (3) 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 sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259). (4) Select tenants from the public housing waiting list (see III.N.2, “Special Tests and Provisions – Public Housing Waiting List”) (24 CFR sections 960.206 and 960.208). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR sections 960.253, 960.257, and 960.259). Condition: During testing of 10 tenant files, eligibility related exceptions were identified in 2 files. • In 1 instance, tenant income was improperly excluded, resulting in an inaccurate rent/subsidy calculation. • In 1 instance, tenant income was improperly calculated, resulting in an inaccurate rent/subsidy calculation. Questioned Costs: $2,047 Context: Out of 10 tenant files tested, 2 tenant files contained errors as noted above. Cause: The Authority had inadequate controls over the income verification and calculation processes, including insufficient review procedures to ensure all income sources are properly identified, evaluated, and included in rent calculations. Effect: These deficiencies increase the risk that tenant rent and subsidy amounts are not calculated in accordance with HUD requirements, potentially resulting in: • Overpayments or underpayments of subsidy, • Incorrect tenant rent charges, and • Noncompliance with HUD regulations, which may lead to questioned costs. Repeat Finding: This is a repeat finding from previous years. The finding numbers were 2023-006 and 2024-006. Recommendation: We recommend the Authority strengthen internal controls over income determination and rent calculation by: • Enhancing procedures to ensure all sources of tenant income are properly identified, verified, and included in calculations • Providing additional training to staff on HUD income determination and rent calculation requirements • Implementing or strengthening supervisory review controls to detect and correct errors in a timely manner Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 001 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) 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). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) 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). (3) 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). (4) Use the Enterprise Income Verification (EIV) system in its entirety to verify tenant employment and income information during mandatory reexaminations of family composition and income in accordance with 24 CFR 5.233; and reduce administrative and subsidy payment errors in accordance with 24 CFR 5.236 and other administrative guidance issued by HUD. (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR section 982.516). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 4 The file is missing support for the calculation of HAP. Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 18 The EIV was missing from the file. 3 The file was missing the HUD-9886 authorization form. 3 The file was missing the Authority’s general release form. 12 The Authority did not review the tenant’s information on an annual basis 5 The allowable expenditures included in the file were not included on the 50058 9 The HAP paid was understated 2 The HAP income information reported in the 50058 did not agree to support. Questioned Costs: $12,428 Context: Out of 60 housing voucher cluster tenant files tested, 32 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as its administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, 2022-001, and 2023-001. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Conduct training for program staff on eligibility documentation requirements and program rules. 2. Initiate internal audits of tenant files to identify and correct documentation issues proactively. 3. Establish a monitoring protocol to ensure continued compliance and to prevent recurrence of documentation issues. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 002 – Annual HQS Inspections Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters Criteria or Specific Requirement: The PHA must inspect the unit leased to a family at least biennially 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 the testing of 60 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Annual HQS Inspections Number of Instances Finding 2 The HQS inspection was not performed in a timely manner Questioned Costs: Undeterminable Context: Out of 60 files tested for annual inspections, 2 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, 2022-002, and 2023-002. Recommendation: To ensure compliance with federal requirements, we recommend the Authority takes the following actions: 1. Implement a centralized tracking system to monitor inspection due dates and follow-up timelines to ensure all inspections are completed within the HUD-mandated timeframes. 2. Evaluate staffing levels and consider hiring additional inspectors or contracting third-party services to meet inspection demands. 3. Provide ongoing training on HQS protocols and compliance expectations. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 003 – Rent Reasonableness Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance,Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must determine that the rent to the 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 10 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA 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: During the testing of 80 housing voucher cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 1 The rent reasonableness was not performed prior to the effective date. Questioned Costs: Undeterminable Context: During our testing, we reviewed 80 tenant files that required rent reasonableness determinations; 1 tenant file contained errors as noted above. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unreasonable rent to the landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, 2022-003, and 2023-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 004 – Selection from the Waiting List Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Except as provided in 24 CFR section 982.203 Special admission (nonwaiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Tenant Selected from the Waiting List Number of Instances Finding 6 The tenant was not removed from the waitlist in accordance with policy. Questioned Costs: Undeterminable Context: Out of 60 tenants selected from the waiting list files tested, 6 files contained the errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, 2022-004, and 2023-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are removed from the waiting list timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 005 – PIC Reporting Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances Finding 3 The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 3 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special reporting requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005 and 2023-005. Recommendation: We recommend that the Authority designate an individual to ensure the HUD- 50058s are uploaded into the PIC system accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 006 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (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 household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 960.259). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). (3) 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 sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259). (4) Select tenants from the public housing waiting list (see III.N.2, “Special Tests and Provisions - Public Housing Waiting List”) (24 CFR sections 960.206 and 960.208). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR sections 960.253, 960.257, and 960.259). Condition: During the testing of the Public Housing Program tenant files, a compliance deficiency was noted: Of the 60 tenant files provided, auditor noted the following items: Number of Instances 1 Finding: Tenant income was improperly excluded from the HUD-50058 Questioned Costs: $12,630 Context: Out of 10 public housing tenant files tested, 1 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their ACOP. Effect: The Authority is not in compliance with federal regulations regarding reporting a tenant’s income in the HUD-50058. Repeat Finding: Yes, 2023-006. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2024 – 007 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Opportunities for Persons with Aids Assistance Listing Numbers: 14.241 Federal Award Identification Number and Year: FL080; 2024 Award Period: October 1, 2023 to September 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person’s family, including persons important to their care or well-being, as defined in 24 CFR section 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: During the testing of the HOPWA files, certain eligibility deficiencies were noted as summarized below: Number of Instances Finding 1 There was no support for excluding the income of a full-time college student for the recertification date tested 1 The annual inspection was not performed within a year. Questioned Costs: Undeterminable Context: Out of 29 HOPWA tenant files tested, 2 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their tenant files to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority is not in compliance with federal regulations regarding the verification of the tenants income and maintaining adequate documents per the compliance requirements. Repeat Finding: No. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant’s eligibility and also determine the tenants’ portion of rent and the Authority’s portion of the rent. 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). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) 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). (3) 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). (4) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR section 982.516). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances -- Finding 29 -- The Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances -- Finding 49 -- The income reported on the 50058 was not supported. 34 -- The assets reported on the 50058 was not supported. 35 -- The expenses reported on the 50058 was not supported. 45 -- The Authority did not review the tenant’s information on an annual basis 40 -- The file was missing the HUD-9886 authorization form. 41 -- The file was missing the Authority general release form. 48 -- The Audit Memo Trail in Yardi was not approved by the housing specialist. 49 -- The HAP information reported in the 50058 did not agree to support. 32 -- The HAP Contract could not be verified to supporting documents. 46 -- The Authority's internal control checklist was missing in the tenant file. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 housing choice voucher and mainstream voucher tenant files tested, 49 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as it’s administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements, the calculation of tenant rent and HAP and verification of the tenant’s amounts reported on the HUD-50058. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, 2021-001, and 2022-001. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility determination and verification or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 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 abate HAP payments 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). In addition, all HCV units are required to be inspected annually. 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 the testing of 120 Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Failed HQS Inspections Number of Instances -- Finding 7 -- The Authority did not properly abate HAP after the second failed inspection and/or the tenants passed inspection reports and dates were missing and it could not be verified if the HAP payments were properly abated for the units. Annual HQS Inspections Number of Instances -- Finding 19 -- The annual inspection was not performed in a timely manner, the Authority failed to enforce regulation, or the inspection was unable to be located. 2 -- The Authority's HQS inspection was missing Questioned Costs: Undeterminable; estimated to be over $25,000 Context: Out of 60 files tested for failed inspections, 7 files contained errors as noted above. Out of 60 files tested for annual inspections, 19 files contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely or to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, 2021-002, and 2022-002. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS inspections. We recommend the Authority to hire outside consultants to assist with inspections or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) 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 five percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA 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: During the testing of the Housing Voucher Cluster tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances -- Finding 17 -- The rent reasonableness was not performed prior to the effective date. 5 -- The tenant file did not document completion of rent determination showing 3 comparable for units located in the same area, with similar amenities, size and condition. 5 -- The approved rent determination form was not completed to ensure that it was properly entered into the Yardi system by agreeing it to the rent amount on the HUD 50058. 13 -- The PBV agreement establishing the contract rent for 1 bedroom size units could not be provided. Questioned Costs: Undeterminable; estimated to be over $25,000 Context: During our testing, we reviewed 120 tenant files that required rent reasonableness determinations; 35 tenant files contained errors as noted above with multiple tenant files containing more than one error. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the HAP amount or failed to properly maintain the applicable forms to support the rent reasonableness performed. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, 2021-003, and 2022-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed and was completed in a timely manner. We recommend the Authority to hire outside consultants to assist with reasonable rent determinations or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances -- Finding 25 -- The HUD-52578b Statement of Family Responsibility was signed and completed after the effective date. 14 -- The HUD-52578b Statement of Family Responsibility are missing. 2 -- The referral forms were missing from the tenant files. 2 -- The HUD-52646 vouchers were not properly signed. 14 -- The acceptance letters were missing from the tenant files. 6 -- The original applications were missing from the tenant files. 6 -- The original applications were missing from the tenant files. Tenant Selected from the Waiting List Number of Instances -- Finding 35 -- The tenant was not admitted in accordance with the applicant's selection policies found in the administrative plan. 2 -- The Authority provided status on the open items report but failed to provide supporting documentation or actions taken. 3 -- There was no documentation of reason for the tenant being denied from the program. 1 -- There was no letter notifying the tenant that their name had been selected from the waiting list. Questioned Costs: Undeterminable Context: Out of 60 new tenant files tested, 40 contained the errors noted above. Out of 60 tenants selected from the waiting list files tested, 43 files contained the errors noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, 2021-004, and 2022-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. We recommend that the Authority’s waitlist tracking software be monitored to ensure tenants are notified appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: HUD-50058, Family Report (OMB No. 2577-0083) – The PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA’s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances -- Finding 5 -- The HUD-50058 form was not uploaded to PIC at all 4 -- The HUD-50058 was not uploaded timely or errors were not corrected timely Questioned Costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 9 of which contained errors as noted above. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special report requirements surrounding timely HUD-50058 submission. Repeat Finding: Yes, 2022-005. Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 2023 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (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 household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 960.259). (2) For both family income examinations and reexaminations, obtain and document in the family file third party verification of (a) reported family annual income, (b) the value of assets, (c) expenses related to deductions from annual income, and (d) other factors that affect the determination of adjusted income or income-based rent (24 CFR section 960.259). (3) 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 sections 5.601 et seq., and 24 CFR sections 960.253, 960.255, and 960.259). (4) Select tenants from the public housing waiting list (see III.N.2, “Special Tests and Provisions – Public Housing Waiting List”) (24 CFR sections 960.206 and 960.208). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR sections 960.253, 960.257, and 960.259). Condition: During the testing of the Public Housing Program tenant files, a compliance deficiency was noted: Of the 60 tenant files provided, auditor noted the following items: Number of Instances -- Finding 5 -- The tenant file was missing a signed 9886 general release form for one or more of the residents. 4 -- The tenant file was missing a signed 214 form for one or more tenants. 9 -- The quality control checklist was not signed by the housing specialist. 1 -- The recertification was not completed for the selected effective date. 6 -- The income reported on the HUD-50058 was incorrectly reported or support could not be provided for the reported income. 3 -- The family income and composition was not reexamined annually. 1 -- The expenses reported on the HUD-50058 was incorrectly reported. 2 -- The assets reported on the HUD-50058 was incorrectly reported. Undeterminable; estimated to be over $25,000 Context: Out of 60 public housing tenant files tested, 22 tenant files contained errors as noted above. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their ACOP. Effect: The Authority is not in compliance with federal regulations regarding the verification of the tenants income and maintaining adequate documents per the compliance requirements. Repeat Finding: No. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month and to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility requirements or increase staffing in this area. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Low Rent Public Housing Assistance Listing Numbers: 14.850 Federal Award Identification Number and Year: FL080; 20223 Award Period: October 1, 2022 to September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or Specific Requirement: The PHA must establish and adopt written policies for admission of tenants. The PHA tenant selection policies must include requirements for applications and waiting lists, description of the policies for selection of applicants from the waiting lists, and policies for verification and documentation of information relevant to acceptance or rejections of an applicant (24 CFR sections 960.202 through 960.206). Condition: During the testing of the Low Rent Public Housing Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants The Housing Authority failed to follow and enforce it's ACOP in adding families to the waiting list. Rent Cafe was used for adding families to the waiting list. However, the Housing Authority could not verify the workflow in adding families to the waiting list upon receiving an application in Rent Cafe. Also, during the fiscal year, they noticed applicants were left on Rent Cafe, without pushing the application to Yardi. This resulted in those families not being properly selected from the waitlist. Tenant Selected from the Waiting List Number of Instances -- Finding 8 -- The housing authority failed to provide documentation showing date/time of the original application through Rent Cafe or any other alternate system. 7 -- The housing authority did not follow controls for selection of the families from the waiting list. Questioned Costs: Undeterminable Context: We were unable to test a sample of waiting list-new tenants due to the Authority not properly tracking new tenants. Out of 8 tenants files tested for selection from the waiting list, 8 files contained errors noted above. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority is not in compliance with federal regulations regarding the verification of the tenants income and maintaining adequate documents per the compliance requirements. Repeat Finding: No. Recommendation: We recommend management review policies and procedures in place and develop work processes to ensure it is in compliance with the ACOP and HUD. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2022 ? 001 ? Eligibility Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Award Period: October 1, 2021 to September 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Other Matters Criteria or specific requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant?s eligibility and also determine the tenants? portion of rent and the Authority?s portion of the rent. 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). The PHA must do the following: (1) As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). (2) 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). (3) 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). (5) Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification (24 CFR section 982.516). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 11 Where the Authority was unable to provide a tenant file to review Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Finding 2022 ? 001 ? Eligibility Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 46 Where the file was missing the Section 214 Declaration for family members 46 Where the income, assets, or expenses calculated on the 50058 was not supported 46 Where the Authority did not review the information on an annual basis 38 Where the file was missing the HUD-9886 authorization form 37 Where the file was missing the Authority general release form 23 Where the HAP information from the 50058 did not agree to support 23 Where the HAP Contract could not be verified to supporting documents 45 Where the Housing Choice Voucher?s tenant file was missing the preparer checklist that is utilized as an internal control to ensure all required elements are in the tenant file Questioned costs: Undeterminable. Context: Out of 60 housing choice vouchers and mainstream tenant files tested, 56 tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations, as well as their administrative plan. Effect: The Authority is not in compliance with federal regulations regarding eligibility requirements and the calculation of the rent and verification of the tenant?s income. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, 2020-001, and 2021-001. Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2022 ? 002 ? HQS Enforcements and Annual HQS Inspections Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Award Period: October 1, 2021 to September 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Other Matters Criteria or specific requirement: 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 abate HAP payments 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). In addition, all HCV units are required to be inspected annually. 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 the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Failed HQS Inspections Number of Instances Finding 3 Where the passed inspection reports were missing and could not verify if the payments were properly abated for the units. 19 Where the Authority did not properly abate HAP after the second failed inspection and/or the tenants passed inspection reports and dates were missing and could not verify if the payments were properly abated for the units. Annual HQS Inspections Number of Instances Finding 23 Where the annual inspection was not performed in a timely manner, the Authority failed to enforce regulation, or the inspection was unable to be located Questioned costs: $94,160 Context: Out of 60 failed inspections tested, 22 inspections contained errors as noted above. Out of 60 annual inspections, tested 23 inspections contained errors as noted above. Cause: The Authority does not have adequate procedures in place to ensure units are inspected timely or to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, 2020-002, and 2021-002. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2022 ? 003 ? Rent Reasonableness Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Award Period: October 1, 2021 to September 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) 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 five percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA 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: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 21 Where the rent reasonableness was not performed prior to the effective date 13 Where the Go Section 8 form for rent reasonableness could not be provided 7 Where the 50058 form was missing for the rent reasonableness performed. 10 Where the Go Section 8 form was not signed 7 Where the auditor cannot review the previous 50058 to verify if the rent increase was processed on current transaction. Questioned costs: Undeterminable Context: During our testing, we reviewed 120 tenant files that required a rent reasonableness; 29 tenant files contained errors as noted above with multiple tenant files containing more than one error. The sample was a statistically valid sample. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the tenant file or failed to properly maintain the applicable forms to support the rent reasonableness performed. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, 2020-003, and 2021-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2022 ? 004 ? Selection from the Waiting List Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Award Period: October 1, 2021 to September 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Other Matters Criteria or specific requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. ?Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances Finding 2 Where the Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 11 Where the tenant was not admitted correctly into the program with accordance into the admin plan due to either the original application and/or acceptance/referral letter was missing. 2 Where the tenant file did not contain the tenant?s original application 10 Where the tenant file did not contain the letter notifying them that they had been accepted into the Housing Choice Voucher Program 1 Where a referral letter was missing for a special program Tenant Selected from the Waiting List Number of Instances Finding 34 Where the status of the applicant was showing "selected" since 2022, noting the Authority's lack of maintenance of the Waiting List 34 Where the Authority provided status on the open items report, but failed to provide supporting documentation or actions taken. Questioned costs: Undeterminable Context: Out of 60 new tenant files tested, 13 contained the errors noted above. Out of 60 tenants selected from the waiting list files tested, 34 files contained the errors noted above. The sample was a statistically valid sample. Finding 2021 ? 004 ? Selection from the Waiting List (Continued) Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations as well as their administrative policy. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, 2020-005, and 2021-004. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2022 ? 005 ? PIC Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Award Period: October 1, 2021 to September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or specific requirement: The PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection The PHA is required to submit this form electronically to HUD each time the PHA completes an admission, annual reexamination, interim reexamination, portability move-in, or other change of unit for a family. The PHA must also submit the Family Report when a family ends participation in the program or moves out of the PHA?s jurisdiction under portability (24 CFR Part 908 and 24 CFR section 982.158). (24 CFR sections 982.158(d) and 982.405(b)). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to ensure that special reporting requirements were being met. Number of Instances Finding 11 Where the HUD-50058 form was not uploaded to PIC at all 13 Where the HUD-50058 was not uploaded timely or errors were not corrected timely Questioned costs: Undeterminable Context: During our testing, we reviewed 60 HUD-50058 PIC uploads, 24 of which contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority does not have adequate internal controls designed to ensure that special reporting requirements were being met. Effect: The Authority is not in compliance with program requirements over special report requirements surrounding timely HUD-50058 submission. Repeat Finding: No Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2021 ? 001 ? Eligibility Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Numbers:14.871 and 14.879 Award Period: October 1, 2020 to September 30, 2021 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant?s eligibility and also determine the tenants? portion of rent and the Authority?s portion of the rent. 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 CRF section 982.516). Determine income eligibility and calculated the tenant?s rent payment using the documentation from third-party verification in accordance with 24 CRF part 5 subpart F (24 CFR section 5.601 et seq.)(24 CFR sections 982.201, 982.515, and 982.516). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Number of Instances Finding 13 Where the Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 20 Where the file was missing the Section 214 Declaration for family members 35 Where the income, assets, or expenses calculated on the 50058 was not supported 21 Where the Authority did not review the information on an annual basis 25 Where the file was missing the HUD-9886 authorization form 28 Where the file was missing the Authority general release form 6 Where the HAP information from the 50058 did not agree to support 36 Where the HAP Contract could not be verified to supporting documents 47 Where the Housing Choice Voucher?s tenant file was missing the preparer checklist that is utilized as an internal control to ensure all required elements are in the tenant file 6 Where the Emergency Housing Voucher?s tenant file was missing the preparer checklist that is utilized as an internal control to ensure all required elements are in the tenant file Questioned costs: Undeterminable. Context: Out of 60 housing choice vouchers and mainstream tenant files tested, 60 tenant files contained errors as noted above. In addition, we tested 6 emergency housing vouchers, 6 emergency housing voucher tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations. Effect: The Authority is not in compliance with federal regulations regarding the calculation of the rent and verification of the tenants? income. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-001, 2018-001, 2019-001, and 2020-001. Recommendation: We recommend management designate one person to review a sample of tenant files each month, to determine if the tenant files were prepared in accordance with internal policies. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2021 ? 002 ? HQS Enforcements Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Numbers:14.871 and 14.879 Award Period: October 1, 2020 to September 30, 2021 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: 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 abate HAP payments 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). In addition, all HCV units are required to be inspected annually. Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: HQS Enforcement Number of Instances Finding 5 Where the passed inspection reports were missing and could not verify if the payments were properly abated for the units. 3 Where the re-inspections were not completed within 30 calendar days of the initial failed inspection. 8 Where the Authority did not abate the HAP payments properly after the second failed inspection. Questioned costs: $15,720 Context: Out of 60 failed inspections 13 tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority does not have adequate procedures in place to ensure units are re-inspected timely and to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-002, 2018-002, 2019-002, and 2020-002. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2021 ? 003 ? Rent Reasonableness Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Numbers:14.871 and 14.879 Award Period: October 1, 2020 to September 30, 2021 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) 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 five percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA 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: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 22 Where the rent reasonableness information was missing 9 Where the reasonable rent was approved after the effective date Questioned costs: Undeterminable Context: During our testing, we reviewed 107 tenant files that required a rent reasonableness; 29 tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the tenant file. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2017-003, 2018-003, 2019-003, and 2020-003. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2021 ? 004 ? Selection from the Waiting List Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster Assistance Listing Numbers: 14.871 and 14.879 Award Period: October 1, 2020 to September 30, 2021 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. ?Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances Finding 2 Where the Authority was unable to provide a tenant file to review Of the files the Authority was able to provide. The files contained the following compliance deficiencies: Number of Instances Finding 1 Where the tenant file did not contain the tenant voucher 12 Where the tenant file did not contain the tenant application 13 Where the tenant file did not contain the letter notifying them they had had been accepted into the Housing Choice Voucher Program Tenant Selected from the Waiting List Number of Instances Finding 43 Where the Authority did not properly follow their administrative plan in regarding to removing tenants from the waiting listing 1 Where the Authority was not able to provide documentation showing that the tenant has been properly removed from the waitlist Questioned costs: Undeterminable Context: Out of 17 new tenant files tested, 15 contained the errors noted above. Out of 60 tenants selected from the waiting list files tested, 43 files contained the errors noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight of their waiting list to ensure compliance with HUD rules and regulations. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are no longer interested in the HCVP housing, or have moved away. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, and 2020-005. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2021 ? 005 ? Eligibility (Housing Opportunities for Person with AIDS) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Opportunities for Person with AIDS (HOPWA) Assistance Listing Number:14.241 Pass-Through Agency: City of West Palm Beach, FL Award Period: October 1, 2020 to September 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance (Other Matters) Criteria or specific requirement: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person?s family, including persons important to their care or well-being, as defined in 24 CFR section 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: During the testing of the Housing Opportunities for Person with AIDS (HOPWA) files, certain eligibility deficiencies were noted as summarized below: Number of Instances Finding 2 Where the tenant file did not contain current proof of income for the recertification date. 3 Where the annual inspection was not performed within a year 10 Where the filed did not contain a release form or a self-attestation form Questioned costs: Undeterminable Context: During our testing, we reviewed 60 tenant files, 10 of the tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to keep documentation to support eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding the calculation of the rent and verification of the tenant?s income and residency. Repeat Finding: This is a repeat finding from previous years. The finding numbers are 2018-008, 2019-007, and 2020-005. Recommendation: We recommend management designate one person to review a sample of tenant files each month, to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2020 ? 001 ? Eligibility (Repeat from 2017-001, 2018-001, 2019-001) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster CFDA Number: 14.871 and 14.879 Award Period: October 1, 2019 to September 30, 2020 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant?s eligibility and also determine the tenants? portion of rent and the Authority?s portion of the rent. 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 CRF section 982.516). Determine income eligibility and calculated the tenant?s rent payment using the documentation from third-party verification in accordance with 24 CRF part 5 subpart F (24 CFR section 5.601 et seq.)(24 CFR sections 982.201, 982.515, and 982.516). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Eligibility Number of Instances Finding 55 Where the Authority?s checklist was missing. 28 Where the Authority?s general release form was missing. 21 Where the tenant file was missing the Section 214 Declaration for a family member. 21 Where the tenant file was missing the HUD-9886 authorization form. 17 Where the income, assets, or expenses calculated on the 50058 was not supported. 4 Where the Authority was unable to provide the tenant file to review. 3 Where the HAP information from the 50058 form did not agree to supporting documentation. Questioned costs: Undeterminable. Context: Out of 60 tenant files tested, 60 tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations. Effect: The Authority is not in compliance with federal regulations regarding the calculation of the rent and verification of the tenants? income. Recommendation: We recommend management designate one person to review a sample of tenant files each month, to determine if the tenant files were prepared in accordance with internal policies. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2020 ? 002 ? HQS Enforcements and Inspections (Repeat from 2017-002, 2018-002, 2019-002) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster CFDA Number: 14.871 and 14.879 Award Period: October 1, 2019 to September 30, 2020 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: 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 abate HAP payments 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). In addition, all HCV units are required to be inspected annually. Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Housing Quality Standards Inspections Number of Instances Finding 15 Where the tenant file was missing the annual inspection documentation or the tenant file was not provided to verify an inspection was completed. HQS Enforcement Number of Instances Finding 6 Where the passed inspection reports were missing and could not verify if the payments were properly abated for the units. 3 Where the re-inspections were not completed within 30 calendar days of the initial failed inspection. 2 Where the Authority did not abate the HAP payments properly after the second failed inspection. Questioned costs: $5,971 Context: Out of 60 annual inspections 15 tenant files contained errors as noted above. Out of 60 failed inspections 11 tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority does not have adequate procedures in place to ensure units are re-inspected timely and to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspection are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2020 ? 003 ? Rent Reasonableness (Repeat from 2017-003, 2018-003, 2019-003) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster CFDA Number: 14.871 and 14.879 Award Period: October 1, 2019 to September 30, 2020 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) 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 five percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA 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: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 21 Where the rent reasonableness information was missing. Questioned costs: Undeterminable Context: During our testing, we reviewed 87 tenant files that required a rent reasonableness; 21 tenant file contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the tenant file. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2020 ? 004 ? Selection from the Waiting List (Repeat from 2017-004, 2018-004, 2019-004) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster CFDA Number: 14.871 and 14.879 Award Period: October 1, 2019 to September 30, 2020 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. ?Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Waiting List New Tenants Number of Instances Finding 51 Where the original application could not be located. 37 Where the admission letter notifying the tenant they had been accepted into the program could not be located. 22 Where the tenant?s signed voucher was missing. 13 Where the new admission 50058 form was missing. Questioned costs: Undeterminable Context: During our testing, we reviewed 60 new tenant files that were pulled from the waiting list, noting the number of error instances as listed above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are longer interested in the HCVP housing, or have moved away. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2020 ? 005 ? Eligibility (Housing Opportunities for Person with AIDS) (Repeat from 2018-008, 2019-007) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Opportunities for Person with AIDS (HOPWA) CFDA Number: 14.241 Pass-Through Agency: City of West Palm Beach, FL Award Period: October 1, 2019 to September 30, 2020 Type of Finding: Significant Deficiency, Noncompliance (Other Matters) Criteria or specific requirement: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person?s family, including persons important to their care or well-being, as defined in 24 CFR section 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: During the testing of the Housing Opportunities for Person with AIDS (HOPWA) files, certain eligibility deficiencies were noted as summarized below: Number of Instances Finding 5 Where the tenant file did not contain current proof of income or assets for the recertification date. Questioned costs: Undeterminable Context: During our testing, we reviewed 60 tenant files, 5 of the tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to keep documentation to support eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding the calculation of the rent and verification of the tenant?s income and residency. Recommendation: We recommend management designate one person to review a sample of tenant files each month, to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019 ? 001 ? Eligibility (Repeat from 2017-001, 2018-001) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster CFDA Number: 14.871 and 14.879 Award Period: October 1, 2018 to September 30, 2019 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Authority must complete form HUD-50058 for each Housing Choice Voucher (HCV) and Mainstream Voucher tenant. Form HUD-50058 is used to determine a tenant?s eligibility and also determine the tenants? portion of rent and the Authority?s portion of the rent. 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 CRF section 982.516). Determine income eligibility and calculated the tenant?s rent payment using the documentation from third-party verification in accordance with 24 CRF part 5 subpart F (24 CFR section 5.601 et seq.)(24 CFR sections 982.201, 982.515, and 982.516). Condition: During testing of tenant files, certain eligibility and reporting compliance deficiencies were noted as summarized below: Eligibility Number of Instances Finding 30 Where the Authority?s checklist was either missing or not signed by a housing specialist. 6 Where the income, assets, or expenses calculated on the 50058 was not supported 4 Where the tenant file was missing the Section 214 Declaration for a family member. 1 Where the Housing Assistance Payment amount per the tenant?s file did not match Housing Assistance Payment that was paid. 1 Tenant where the Authority was unable to provide the tenant file. 1 Tenant where the Authority was unable to provide the supporting documents for the request 50058 form. Questioned costs: Undeterminable. Context: Out of 60 tenant files tested, 37 tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations. Effect: The Authority is not in compliance with federal regulations regarding the calculation of the rent and verification of the tenants? income. Recommendation: We recommend management designate one person to review a sample of tenant files each month, to determine if the tenant files were prepared in accordance with internal policies. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019 ? 002 ? HQS Enforcements and Inspections (Repeat from 2017-002, 2018-002) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster CFDA Number: 14.871 and 14.879 Award Period: October 1, 2018 to September 30, 2019 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: 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 abate HAP payments 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). In addition, all HCV units are required to be inspected annually. Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Housing Quality Standards Inspections Number of Instances Finding 13 Tenant did not have their unit inspected on an annual basis. HQS Enforcement Number of Instances Finding 45 In which the Authority could not provide documentation that they notified the landlord or tenant that the unit had failed the inspection. 28 In which the Authority did not re-inspect the tenants? units within the 30 days of the initial failed inspection. 16 In which the Authority did not abate the Housing Assistance Payments after the second failed inspection. 12 In which the Authority did not re-inspect after the initial failed inspection. Questioned costs: $41,956 Context: Out of 60 annual inspections 13 tenant files contained errors as noted above. Out of 60 failed inspections 52 tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority does not have adequate procedures in place to ensure units are re-inspected timely and to ensure that units with housing quality standard deficiencies are not paid housing assistance payments. Effect: The Authority is not in compliance with federal regulations regarding minimum housing quality standards and was paying housing assistance for units that did not meet these standards. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspection are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019 ? 003 ? Rent Reasonableness (Repeat from 2017-003, 2018-003) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster CFDA Number: 14.871 and 14.879 Award Period: October 1, 2018 to September 30, 2019 Type of Finding: Significant Deficiency, Noncompliance (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 five percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA 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: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 1 The rent reasonableness was performed after the effective date. Questioned costs: Undeterminable Context: During our testing, we reviewed 37 tenant files that required a rent reasonableness; 1 tenant file contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to determine the reasonableness of the rent being charged before the effective date of the tenant file. Effect: The Authority is not in compliance with federal regulations regarding the determination of reasonable rent. Inaccurate data could cause Authority to be paying an unfair rent to a landlord. Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019 ? 004 ? Selection from the Waiting List (Repeat from 2017-004, 2018-004) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Choice Voucher Cluster CFDA Number: 14.871 and 14.879 Award Period: October 1, 2017 to September 30, 2018 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants for admission from the waiting list. Expect as provided in 24 CFR section 982.203 (Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. ?Selection from the waiting list generally occurs when the PHA notifies a family whose names reaches the top of the waiting list to come in to verify eligibility for admission (24 CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: During the testing of the Housing Choice Voucher Program tenant files, certain special provision compliance deficiencies were noted as summarized below: Top of the Waiting List Number of Instances Finding 3 The Authority was unable to locate the tenant file. Waiting List New Tenants Number of Instances Finding 12 The admission letter notifying the tenant they had been accepted into the program could not be located. 7 The tenant?s voucher was not signed by the tenant or HCVP Specialist or the voucher could not be located. 1 The original application could not be located. Questioned costs: Undeterminable Context: During our testing, we reviewed 60 tenant files of tenant that had reached the top of the waiting list and 30 new tenant files that were pulled from the waiting list, noting the number of error instances as listed above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations. Effect: The Authority may have tenants on the waiting list that are not eligible for an HCVP voucher, are longer interested in the HCVP housing, or have moved away. Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019 ? 005 ? Eligibility (Public Housing) (Repeat from 2018-006) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Public and Indian Housing CFDA Number: 14.850 Award Period: October 1, 2018 to September 30, 2019 Type of Finding: Significant Deficiency, Noncompliance (Other Matters) Criteria or specific requirement: PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. PHAs must reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary using the documentation from third-party verification (24 CFR sections 960.253, 960.257, and 960.259). Condition: During the testing of the Public and Indian Housing tenant files, certain eligibility provision compliance deficiencies were noted as summarized below: Number of Instances Finding 1 Tenant?s file did not contain the Section 214 Declaration for one of the family members. 1 Tenant?s file did not contain supporting documents for the effective date reviewed. 1 Tenant?s rent per the 50058 form did not agree to the rent roll. Questioned costs: Undeterminable Context: During our testing, we reviewed 60 tenant files, noting the number of error instances as listed above. The sample was a statistically valid sample. Cause: The Authority failed to provide adequate monitoring and oversight to ensure compliance with HUD rules and regulations. Effect: The Authority is not in compliance with federal regulations regarding the calculation of the rent and verification of the tenant?s income and following their administrative policy. Recommendation: We recommend management designate one person to review a sample of tenant files each month, to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019 ? 006 ? Procurement (Repeat from 2018-007) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Public and Indian Housing CFDA Number: 14.850 Award Period: October 1, 2018 to September 30, 2019 Type of Finding: Significant Deficiency, Noncompliance (Other Matters) Criteria or specific requirement: The Entity should meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. The Entity should conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition: During the testing of the Public Housing contract files, certain eligibility deficiencies were noted as summarized below: Number of Instances Finding 4 The Authority did not follow their policy with contracts that had expenses during the fiscal year as they did not go through the procurement process. Questioned costs: Undeterminable Context: During our testing, we reviewed 8 contracts, 4 of the contracts contained the error noted above. The sample was a statistically valid sample. Cause: The Authority failed to follow their procurement policy. Effect: The Authority is out of compliance by not following their procurement policy. Recommendation: We recommend management review all major vendors and determine if those vendor have gone through the proper procurement process. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019 ? 007 ? Eligibility (Housing Opportunities for Person with AIDS) (Repeat from 2018-008) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Opportunities for Person with AIDS (HOPWA) CFDA Number: 14.241 Pass-Through Agency: City of West Palm Beach, FL Award Period: October 1, 2018 to September 30, 2019 Type of Finding: Significant Deficiency, Noncompliance (Other Matters) Criteria or specific requirement: A person eligible for assistance under this program means a person with HIV or AIDS who is a low-income individual and the person?s family, including persons important to their care or well-being, as defined in 24 CFR section 574.3. The eligibility of those tenants who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent and order of selection; and (2) obtaining third-party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information. Condition: During the testing of the Housing Opportunities for Person with AIDS (HOPWA) files, certain eligibility deficiencies were noted as summarized below: Number of Instances Finding 2 Tenant file did not contain current proof of income or assets for the recertification date. Questioned costs: Undeterminable Context: During our testing, we reviewed 60 tenant files, 2 of the tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to keep documentation to support eligibility requirements. Effect: The Authority is not in compliance with federal regulations regarding the calculation of the rent and verification of the tenant?s income and residency. Recommendation: We recommend management designate one person to review a sample of tenant files each month, to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019 ? 008 ? HQS Inspections (Housing Opportunities for Person with AIDS) (Repeat from 2018-009) Federal agency: U.S. Department of Housing and Urban Development Federal program title: Housing Opportunities for Person with AIDS (HOPWA) CFDA Number: 14.241 Pass-Through Agency: City of West Palm Beach, FL Award Period: October 1, 2018 to September 30, 2019 Type of Finding: Material Weakness, Material Noncompliance (Modified Opinion) Criteria or specific requirement: All housing that involves acquisition, rehabilitation, conversion, lease, repair of facilities, new construction, project- or tenant-based rental assistance (including assistance for shared housing arrangements), and operating costs must meet various housing quality standards listed in 24 CFR sections 574.310(b)(1)-(2). The grantee should perform inspections of the units and ensure that any needed repairs were completed timely. Condition: During the testing of the Housing Opportunities for Person with AIDS (HOPWA) tenant files, certain special provision compliance deficiencies were noted as summarized below: Number of Instances Finding 18 The Authority did not re-inspect failed units within a year of the recertification date. Questioned costs: Undeterminable Context: During our testing, we reviewed 60 tenant files, 18 of the tenant files contained errors as noted above. The sample was a statistically valid sample. Cause: The Authority failed to follow up with the failed inspections that should be fixed in a timely manner. Effect: The Authority is not in compliance with federal regulations regarding the units not meeting the housing standards. Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed and meeting standards in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.

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