Housing Authority of Brevard CountyLocal Government

2025-001 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream – Vouchers CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2024-001 from March 31, 2024 (initially occurred as Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,849 tenants, 25 files were selected for testing. Exceptions were noted as follows: • 3 tenant file errors where there was no EIV form for the recertification period. • 1 tenant file error where the Form 50058 reported an incorrect utility allowance, and correcting the allowance would decrease the HAP rent from $1,179 to $1,174. • 1 tenant file error where the authority stated they did not have the lease on file. • 1 tenant file error where the Form 50058 reported an incorrect utility allowance, and correcting the allowance would increase the HAP rent from $731 to $751. • 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $740 to $820: o An incorrect utility allowance was reported on the Form 50058. o Tenant’s social security income was miscalculated and reported incorrectly on the Form 50058. • 1 tenant file error where the Form 50058 reported an incorrect utility allowance, and correcting the allowance would decrease the HAP rent from $851 to $789. • 1 tenant file error where the Form 50058 reported an incorrect utility allowance, and correcting the allowance would increase the HAP rent from $986 to $1,016. • 1 tenant file had the following errors: o No EIV form on file for the recertification period. o Income support was not obtained by the Authority. • 1 tenant file error where tenant wage income was calculated incorrectly. Correcting the income issue would increase the HAP rent from $1,604 to $1,625. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by transitioning the Authority’s core management software from Tenmast to Yardi during the fiscal year. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2024-001 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream – Vouchers CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding (the prior year finding was a significant deficiency) of 2023-002 from March 31, 2023 (initially occurred as Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows: • 1 tenant file had the following errors: o Miscalculation of social security income reported on the form 50058 (used a prior year SSI instead of the current year). Correcting this error would decrease the HAP rent from $1,610 to $1,567. o One missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen. • 1 tenant file had the following errors: o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens. o The 9886 form was not dated. Thus, we do not know if the 9886 form was signed within 15 month required timeframe. • 1 tenant file had the following errors: o Missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen. o The tenant did not sign and date the Form 9886. • 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $1,130 to $1,159: o Miscalculation of social security income reported on the 50058. o Miscalculation of medical expense reported on the 50058. • 1 tenant file error where a member of the household over the age of 18 did not sign the Form 9886. • 1 tenant file error where social security income was calculated incorrectly. Correcting the income would decrease the HAP rent from $1,155 to $1,153. • 1 tenant file error where a member of the household over the age of 18 did not sign the 9886. • 1 tenant file error where the tenant dated the year on the 9886 form 2013 when it should be 2023. • 1 tenant file error where a member of the household over 18 years old did not sign Form 9886. • 1 tenant file error where the Form 50058 reported an incorrect utility allowance, but correcting the allowance would not change the HAP rent amount. • 1 tenant file error where the tenant’s wage income was miscalculated. However, correcting the error would have no effect on the HAP rent amount. • 1 tenant file error where there was no EIV form for the recertification period. • 1 tenant file error where tenant wage income was calculated incorrectly. Correcting these income issues would decrease the HAP rent from $1,207 to $896. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $1,378 to $1,030: o An incorrect utility allowance was reported on the Form 50058. o Income support was not reported correctly on the Form 50058. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificate, the household member is a U.S. citizen. o Support for tenant’s pension income was over 12 months old. • 1 tenant file error where child support income was calculated incorrectly. However, correcting the error would have no effect on the HAP rent amount. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2024-002 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2023-003 from March 31, 2023 (initially occurred as Finding 2022-004 from March 31, 2022) Condition: 25 out of 250 new admissions were selected for testing. Exceptions were noted as follows: • 15 new admissions where the selection from the waiting list was not in compliance with the Authority’s administrative plan. The administrative plan states that that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). However, the applicants tested were ranked randomly through a lottery. Due to this issue, there were many applicants that were not ranked properly on the waiting list and were thus not admitted in proper sequence into the Section 8 program. • 4 new admissions where the Authority was unable to provide support that the applicants were properly selected from the waiting list (as the waiting list for the new admissions that were selected from was not retained). • 1 new admission where the Authority did not sign the lease agreement and the unit address and rent amount on the lease agreement did not agree to the Form 50058. • 1 new admission where the Authority could not provide the tenant’s voucher. Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program. Questioned Costs: None. Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2024-003 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income Public and Indian Housing Program – CFDA 14.850 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2023-004 from March 31, 2023 (originally reported as finding 2022-005 from March 31, 2022) Criteria: The Authority receive invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to Form 52722 to calculate the utility expense level (UEL). The UEL is a primary component of the operating subsidy grant revenue of the Authority, which is calculated on Form 52723. Form 52723 uses a formula to calculate the Operating Fund Revenue for the Authority. The calculation is generally based on prepopulated data calculated by HUD. However, in some cases, the formulaic fields are not prepopulated. Form 52722 and 52723 need to be reported correctly to ensure the operating subsidy grant revenue is calculated correctly for the future period. Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion. Cause: Former employees of the Authority did not retain the utility ledger. Effect: The Authority did not retain the utility ledger as required by HUD. The Authority is not in compliance with this reporting requirement. Failure to properly maintain records could lead to significant issues in funding. Questioned Cost: None Recommendation: The Authority should retain the utility ledger for each fiscal year under audit. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to retain the utility ledger. We will retain the utility ledger for each fiscal year under audit.

2023-001 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2022-002 from March 31, 2022 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing reported the PIH FSS activity under CFDA #14.870 Resident Opportunity and Supportive Services when it should have been reported under CFDA #14.896 PIH Family Self-Sufficiency Program. In addition, the $761,718 of CFP subsidy was reported under CFDA #14.850 Public and Indian Housing when it should have been reported under CFDA #14.872 Public Housing Capital Fund. Furthermore, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on July 30, 2024 (the due date was May 30, 2023). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2023 at completion of the single audit, but was not filed timely as the audit was completed on November 8, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect misclassified financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2023-002 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance This is a repeat finding of 2022-003, reported as a Material Weakness from March 31, 2022 (initially occurred as Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows: • 1 tenant file had the following errors: o General assistance income was included in income when it should have been excluded. Correcting this error would increase the HAP rent from $958 to $1,027. o One missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen. • 1 tenant file had the following errors: o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens. o The tenant’s medical expense was misreported on the 50058. However, the error had no effect on the HAP rent. • 1 tenant file error for one missing 214 affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $846 to $724: o Miscalculation of social security income reported on the 50058. o Miscalculation of medical expense reported on the 50058. o Miscalculation of the tenant’s annual unreimbursed childcare costs reported on the 50058. • 1 tenant file error where a member of the household over the age of 18 did not sign the 9886. • 1 tenant file had the following errors and correcting the errors would have no effect on the HAP rent: o Food assistance was included as income when it should have been excluded. o The tenant’s utility allowance was misreported on the 50058. • 1 tenant file error where the tenant’s utility allowance was misreported and correcting the error would decrease the HAP rent from $1,198 to $1,183. • 1 tenant fille error where the tenant did not sign the lease agreement. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2023-003 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2022-004 from March 31, 2022 Condition: 14 out of 137 new admissions were selected for testing, but testing was suspended after testing 8 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file had the following errors: o The tenant signed the request for tenancy approval form after the voucher expiration date. o The Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenant was not admitted properly into the Section 8 program. • 1 tenant file error where the tenant and landlord signed the request for tenancy approval form after the voucher expiration date. • 5 tenant file errors where the Authority did not follow their administrative plan when selecting applicants for admission. As a result, the tenants were not admitted properly into the Section 8 program. • 1 tenant file error where the tenant was selected from the tenant-based mainstream waiting list. A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority's administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority's system through a lottery ranking technique. This is not in compliance with the Authority's administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program. Questioned Costs: None. Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2023-004 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income Public and Indian Housing Program – CFDA 14.850 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2022-005 from March 31, 2022 Criteria: The Authority receives invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to Form 52722 to calculate the utility expense level (UEL). The UEL is a primary component of the operating subsidy grant revenue of the Authority, which is calculated on Form 52723. Form 52723 uses a formula to calculate the Operating Fund Revenue for the Authority. The calculation is generally based on prepopulated data calculated by HUD. However, in some cases, the formulaic fields are not prepopulated. Form 52722 and 52723 need to be reported correctly to ensure the operating subsidy grant revenue is calculated correctly for the future period. Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion. Cause: Former employees of the Authority did not retain the utility ledger. Effect: The Authority did not retain the utility ledger as required by HUD. The Authority is not in compliance with this reporting requirement. Failure to properly maintain records could lead to significant issues in funding. Questioned Cost: None Recommendation: The Authority should retain the utility ledger for each fiscal year under audit. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to retain the utility ledger. We will retain the utility ledger for each fiscal year under audit.

2022-002 Reporting – Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2021-002 from March 31, 2021 (initially occurred as Finding 2020-002 from March 31, 2020) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority’s original unaudited FDS filing did not include the Authority’s blended component unit. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 10, 2023 (the due date was May 30, 2022). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (“FAC”) by December 31, 2022 at completion of the single audit, but was not filed timely as the audit was completed on September 9, 2024. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect missing financial information and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a correct unaudited FDS within the time frames required by HUD, and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame. Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form.

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority’s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Exceptions were noted as follows: • 3 tenant file errors where the HAP contract was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). • 1 tenant file error where the tenant’s application date, time, and preference did not agree to the date, time, and preference recorded on the waiting list. The tenant should have been housed earlier based on the tenant’s application date, time, and preference. • 1 tenant file had the following errors: o The HAP was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). o The tenant’s application date and time did not agree to the date, time, on the waiting list. The tenant should have been housed earlier based on their application date, time, and preference. • A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority’s administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority’s system through a lottery ranking technique. This is not in compliance with the Authority’s administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Criteria: The Authority must have written policies in its HCVP administrative plan for selecting applicants from the waiting list, and the Authority must show that the Authority has followed these policies when selecting applicants for admission from the waiting list. Also, according to 24 CFR 982.204(f), the Authority must use a single waiting list for admission to its Section 8 tenant-based assistance program. Questioned Costs: None. Effect: The Authority is not properly selecting applicants from the waiting list, and as a result, many applicants were not admitted to the Section 8 program on a first come first serve basis. Cause: Established procedures to ensure compliance with HUD requirements were not being followed. Procedures were not being followed due to employee turnover and other barriers caused by the COVID-19 pandemic. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2022-005 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income Public and Indian Housing Program – CFDA 14.850 Material Weakness in Internal Control and Material Noncompliance Criteria: The Authority receives invoices for utilities. The consumption and cost data from those invoices are aggregated, in an Excel workbook or other platform, commonly referred to as a utility ledger. The aggregated data is transferred to Form 52722 to calculate the utility expense level (UEL). The UEL is a primary component of the operating subsidy grant revenue of the Authority, which is calculated on Form 52723. Form 52723 uses a formula to calculate the Operating Fund Revenue for the Authority. The calculation is generally based on prepopulated data calculated by HUD. However, in some cases, the formulaic fields are not prepopulated. Form 52722 and 52723 need to be reported correctly to ensure the operating subsidy grant revenue is calculated correctly for the future period. Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion. Cause: Former employees of the Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. Furthermore, HUD Form 52722 and 52723 are not accessible to the Authority through HUD’s website. Effect: The Authority did not retain hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger as required by HUD. The Authority is not in compliance with this reporting requirement. Failure to properly maintain records could lead to significant issues in funding. Questioned Cost: None Recommendation: The Authority should retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to locate hard copies or electronic copies of HUD Form 52722, 52723, or the utility ledger. We will retain hard copies or electronic copies of HUD Form 52722, 52723, and the utility ledger for each fiscal year under audit.

2021-002 Reporting ? Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program ? CFDA Number 14.850 Public Housing Capital Fund Program ? CFDA Number 14.872 Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Material Weakness in Internal Control Material Noncompliance Repeat of Finding from March 31, 2020 (Finding 2020-002) Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Condition: The Authority?s original unaudited FDS filing was materially misstated. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on June 28, 2022 (the due date was May 30, 2021). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (?FAC?) by June 30, 2022 (as extended by six months for COVID whereas it was originally due by December 31, 2021) at completion of the single audit, but was not filed timely as the audit was completed on July 12, 2023. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect material misstatement and to file required submissions timely. The Authority experienced business disruptions due to the COVID-19 pandemic including staff absences and turnover. Effect: The Authority did not submit a materially correct unaudited FDS within the time frames required by HUD (as extended), and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame (as extended). Failure to properly file these forms timely could lead to significant issues including delays in funding. Questioned Cost: None Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form (as extended).

2021-003 Eligibility ? Tenant Files Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Significant Deficiency in Internal Control and Other Matter to be Reported Under the Uniform Guidance Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as maintain complete and accurate tenant files. In addition, the Authority?s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows: ? 1 error where the file did not contain any support for $1,200 other income for one member of the household, which could have potentially increased the HAP rent by $12 per month. ? 1 error where the tenant?s child support income was calculated as paid monthly when it was paid weekly, however this had no effect on the HAP rent. In addition to the above, we noted the following during our new admissions testing (15 new admissions tested): ? 2 errors where the lease agreement was not signed prior to move-in. ? 1 error where the lease agreement was not signed by the tenant. ? 2 errors where the HAP contract was more than a year after the beginning of the lease term. ? 1 error where the RFTA was signed but not dated by the tenant. ? 1 error where the RFTA was signed but not dated by the Authority. Cause: Procedures to ensure compliance with all of the HUD requirements were not being fully implemented. The COVID-19 pandemic contributed to the timing of obtaining signatures on the agreements. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertifications, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Questioned Costs: None. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will implement review procedures and provide ongoing training to staff.

2020-002 Reporting ? Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Material Weakness in Internal Control Material Noncompliance Condition: The Authority?s original unaudited FDS filing was materially misstated. In addition, the unaudited FDS filings were not submitted within the timeframes specified by HUD (including extensions provided). The Authority submitted the unaudited FDS filing on June 25, 2021 (of which the normal due date was May 30, 2020 and the extended due date was November 30, 2020). The Authority was also required to submit the OMB Data Collection form to the Federal Audit Clearinghouse (?FAC?) by June 30, 2021 (as extended by six months for COVID whereas it was originally due by December 31, 2020) at completion of the single audit, but it was not filed timely, as the audit was completed on January 31, 2022. Criteria: The Real Estate Assessment Center ("REAC") requires an accurate and timely submission of the unaudited FDS information. The OMB Data Collection Form is due to be electronically filed with the FAC at the completion of a Single Audit (but no later than 9 months after fiscal year end, unless extended). Questioned Cost: None Effect: The Authority did not submit a materially correct unaudited FDS within the time frames required by HUD (as extended), and therefore, was noncompliant with this reporting requirement as well as the requirement to submit the OMB Data Collection Form during the required time frame (as extended). Failure to properly file these forms timely could lead to significant issues, including delays in funding. Cause: The Authority did not have the necessary controls over the period-end financial reporting process to detect material misstatement and to file required submissions timely. The Authority experienced business disruptions due to the ongoing COVID-19 pandemic, including staff absences and turnover. Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Views of Responsible Officials of the Auditee: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the OMB Data Collection Form (as extended).

2019-001 Eligibility ? Tenant Files Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Significant Deficiency in Internal Control Other matter required to be reported in accordance with the Uniform Guidance Condition: Out of a total tenant population of approximately 1900 vouchers, 25 files were selected for testing. Exceptions were noted as follows: ? 2 files with income calculation errors (both files had an immaterial effect on the HAP payment) ? 3 files with lease agreement issues (1 file was missing the lease, 1 file was missing the landlord signature on the lease, and 1 file where the tenant refused to sign the lease) Criteria: 24 CFR 982.516 requires internal controls to be in place to ensure compliance with HUD requirements, as well as complete and accurate tenant files. In addition, the Authority?s administrative plan also requires following proper procedures for determination of HAP and documentation in the tenant files. Questioned Costs: None. Effect: The Authority is not in compliance with all of the HUD requirements regarding eligibility and tenant recertification, which could result in incorrect total tenant payments for rent and HAP payments to landlords. Cause: Procedures to ensure compliance with all of the HUD requirements were not being carefully followed. Auditor?s Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Views of Responsible Officials of the Auditee: The Authority concurs with this finding and will establish more review, oversight and training for the staff responsible for these procedures.

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