EIN: 616001775
UEI: Z52NNQSMJ289
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 19, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 19, 2026 (40 days ago).
What is a management decision? →While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: Yes, 2024-001 Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management’s Response: The PHA has updated the Administrative Plan. Verification requirements are now explicitly stated, including what documentation is acceptable and what is not acceptable as verification. In addition, as the PHA selects applicants from the legacy waiting list, staff confirm the applicant still qualifies for the claimed preference at the time of selection.
Show full finding ▾Hide full finding ▴2025-001 FEDERAL COMPLIANCE – WAITING LIST PREFERENCES Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: According to 24 CFR 982.54(d), the PHA’s administrative plan must include procedures for the “Selection and admission of applicants from the PHA waiting list, including any PHA admission preferences, procedures for removing applicant names from the waiting list, and procedures for closing and reopening the PHA waiting list.” Condition: While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: Yes, 2024-001 Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management’s Response: The PHA has updated the Administrative Plan. Verification requirements are now explicitly stated, including what documentation is acceptable and what is not acceptable as verification. In addition, as the PHA selects applicants from the legacy waiting list, staff confirm the applicant still qualifies for the claimed preference at the time of selection.
The PHA has updated the Administrative Plan. Verification requirements are now explicitly stated, including what documentation is acceptable and what is not acceptable as verification. In addition, as the PHA selects applicants from the legacy waiting list, staff confirm the applicant still qualifies for the claimed preference at the time of selection.
2024-001
During our testing of compliance with Section 8 requirements, we noted several errors while reviewing 40 tenant files. These include the following: • Missing or incomplete HQS/inspection documentation (reports, checklists, or proof of passing; some years not uploaded). • Voucher / Form 50058 (Family Report) missing or incomplete, including support for payment standard/bedroom size used. • Utility reimbursement (UR) and HAP payment changes not supported with required documentation or clear interim/recert support. • Rent reasonableness documentation missing or incomplete, including missing conclusion that rent was reasonable. • Other required file items missing, such as HAP contract, lease pages, eligibility verifications (e.g., birth verification), landlord certification forms, and zero-income forms. Cause: According to the PHA director, these issues were primarily caused by a server crash with the required documentation being unrecoverable. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: Yes, 2024-002 Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management’s Response: The PHA began forwarding requested documentation to the auditors before the server crash impacted its ability to locate and respond to file requests. Once APD recovered the files in September, the PHA resumed providing recovered documentation to fulfill the auditors’ request. To date, the PHA is unable to locate three documents that were originally requested before the crash. The PHA is continuing to sort and review the 12,000+ files that were recovered and will provide any additional responsive documents if they are located. The PHA has revised its recertification/application intake procedures. If a participant submits a recertification packet/application that is incomplete, the PHA will not accept it for processing. Packets must be submitted complete, including all required supporting documentation, before the staff will move forward. In addition, the PHA has strengthened documentation controls to improve file integrity and retrieval going forward. These actions include: • Required intake checklist: The PHA uses a standardized checklist to verify that all required forms and documents are received before a packet is accepted. • File completeness review: The PHA conducts a second-level review to confirm documentation is present and appropriately filed/scanned before final processing. • Standardized scanning and labeling: The PHA scans and labels documents consistently to ensure they can be efficiently located and reproduced for monitoring or audit requests. • Ongoing reconciliation of recovered files: The PHA continues reviewing the 12,000+ recovered files and will provide any additional responsive documents if located, while also using this process to identify and address any gaps in recordkeeping practices. These measures are intended to reduce missing documentation, strengthen file retention practices, and ensure the timely retrieval of records in the future.
Show full finding ▾Hide full finding ▴2025-002 FEDERAL COMPLIANCE – TENANT DOCUMENTATION Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Eligibility and Special Provisions Criteria: HUD requires Public Housing Authorities (PHA) to properly document the eligibility of tenants, properly calculate benefits based on tenant income and determine rent is reasonable. Condition: During our testing of compliance with Section 8 requirements, we noted several errors while reviewing 40 tenant files. These include the following: • Missing or incomplete HQS/inspection documentation (reports, checklists, or proof of passing; some years not uploaded). • Voucher / Form 50058 (Family Report) missing or incomplete, including support for payment standard/bedroom size used. • Utility reimbursement (UR) and HAP payment changes not supported with required documentation or clear interim/recert support. • Rent reasonableness documentation missing or incomplete, including missing conclusion that rent was reasonable. • Other required file items missing, such as HAP contract, lease pages, eligibility verifications (e.g., birth verification), landlord certification forms, and zero-income forms. Cause: According to the PHA director, these issues were primarily caused by a server crash with the required documentation being unrecoverable. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: Yes, 2024-002 Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management’s Response: The PHA began forwarding requested documentation to the auditors before the server crash impacted its ability to locate and respond to file requests. Once APD recovered the files in September, the PHA resumed providing recovered documentation to fulfill the auditors’ request. To date, the PHA is unable to locate three documents that were originally requested before the crash. The PHA is continuing to sort and review the 12,000+ files that were recovered and will provide any additional responsive documents if they are located. The PHA has revised its recertification/application intake procedures. If a participant submits a recertification packet/application that is incomplete, the PHA will not accept it for processing. Packets must be submitted complete, including all required supporting documentation, before the staff will move forward. In addition, the PHA has strengthened documentation controls to improve file integrity and retrieval going forward. These actions include: • Required intake checklist: The PHA uses a standardized checklist to verify that all required forms and documents are received before a packet is accepted. • File completeness review: The PHA conducts a second-level review to confirm documentation is present and appropriately filed/scanned before final processing. • Standardized scanning and labeling: The PHA scans and labels documents consistently to ensure they can be efficiently located and reproduced for monitoring or audit requests. • Ongoing reconciliation of recovered files: The PHA continues reviewing the 12,000+ recovered files and will provide any additional responsive documents if located, while also using this process to identify and address any gaps in recordkeeping practices. These measures are intended to reduce missing documentation, strengthen file retention practices, and ensure the timely retrieval of records in the future.
The PHA has revised its recertification/application intake procedures. If a participant submits a recertification packet/application that is incomplete, the PHA will not accept it for processing. Packets must be submitted complete, including all required supporting documentation, before the staff will move forward. In addition, the PHA has strengthened documentation controls to improve file integrity and retrieval going forward. These actions include: • Required intake checklist: The PHA uses a standardized checklist to verify that all required forms and documents are received before a packet is accepted. • File completeness review: The PHA conducts a second-level review to confirm documentation is present and appropriately filed/scanned before final processing. • Standardized scanning and labeling: The PHA scans and labels documents consistently to ensure they can be efficiently located and reproduced for monitoring or audit requests. • Ongoing reconciliation of recovered files: The PHA continues reviewing the 12,000+ recovered files and will provide any additional responsive documents if located, while also using this process to identify and address any gaps in recordkeeping practices.
2024-002
During our audit, we noted several check runs for the Section 8 program that did not include the finance department’s approval for payment. Additionally, we noted one check that cleared for an amount other than the amount included on the check register. These errors caused increased difficulty in reconciling the bank statements in a timely manner. Cause: According to the PHA director, these differences were caused by the check registers being printed by program instead of check number. Therefore, the payment amount for several tenants for a certain check were listed in a separate section. Other errors were due to misfeeds in the check printer. Effect and Questioned Costs: Reduced effectiveness of internal controls with the possibility of incorrect payments being processed. Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to ensure that checks written agree to the check register prior to mailing and the finance department approve all Section 8 check runs. These procedures should include printing the check register by check number and comparing the printed checks to the register prior to mailing. If any differences are noted due to misfeeds in the check printer, the register should be updated to reflect correct information. Furthermore, an updated check register should be provided to the finance department with a memorandum documenting the changes. The City may consider investing in printing equipment that allows check numbers to be printed on the checks instead of utilizing preprinted checks. Management’s Response: Staff will conduct a manual, check-by-check review immediately after each monthly check run and before mailing to confirm that check totals align with supporting reports. In addition, the PHA will investigate and resolve the source of the discrepancy between the HAPPY Program Management Software outputs and the PHA’s internal control records to ensure consistent and accurate reporting going forward.
Show full finding ▾Hide full finding ▴2025-003 FEDERAL COMPLIANCE - DISBURSEMENTS Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Allowable Costs Criteria: The City’s internal controls require that all disbursements be approved by the finance department prior to payment and that bank reconciliations be performed on all accounts. Condition: During our audit, we noted several check runs for the Section 8 program that did not include the finance department’s approval for payment. Additionally, we noted one check that cleared for an amount other than the amount included on the check register. These errors caused increased difficulty in reconciling the bank statements in a timely manner. Cause: According to the PHA director, these differences were caused by the check registers being printed by program instead of check number. Therefore, the payment amount for several tenants for a certain check were listed in a separate section. Other errors were due to misfeeds in the check printer. Effect and Questioned Costs: Reduced effectiveness of internal controls with the possibility of incorrect payments being processed. Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to ensure that checks written agree to the check register prior to mailing and the finance department approve all Section 8 check runs. These procedures should include printing the check register by check number and comparing the printed checks to the register prior to mailing. If any differences are noted due to misfeeds in the check printer, the register should be updated to reflect correct information. Furthermore, an updated check register should be provided to the finance department with a memorandum documenting the changes. The City may consider investing in printing equipment that allows check numbers to be printed on the checks instead of utilizing preprinted checks. Management’s Response: Staff will conduct a manual, check-by-check review immediately after each monthly check run and before mailing to confirm that check totals align with supporting reports. In addition, the PHA will investigate and resolve the source of the discrepancy between the HAPPY Program Management Software outputs and the PHA’s internal control records to ensure consistent and accurate reporting going forward.
Staff will conduct a manual, check-by-check review immediately after each monthly check run and before mailing to confirm that check totals align with supporting reports. In addition, the PHA will investigate and resolve the source of the discrepancy between the HAPPY Program Management Software outputs and the PHA’s internal control records to ensure consistent and accurate reporting going forward
For Section 8 project-specific vouchers, documentation of contact with individuals selected from the waiting list was not consistently maintained. Files lacked evidence of outreach such as letters, emails, call logs, or documentation of responses and outcomes. Cause: Documentation requirements for waiting list contact were not clearly defined or consistently enforced. Effect and Questioned Costs: Without documentation of outreach efforts, the program cannot demonstrate that project-specific voucher selections were conducted fairly and in compliance with program requirements, increasing risk of noncompliance or disputes. Recommendation: Management should implement a standardized process to document and retain all waiting list contact attempts, including method, dates, and outcomes, in project-specific voucher files. Management’s Response: When applicants call or come in to request a change to contact information, the PHA now requires the applicant to provide the updated information in writing (completed by the applicant) rather than staff updating records solely based on a verbal request. This provides documentation for the change and strengthens file integrity.
Show full finding ▾Hide full finding ▴2025-004 FEDERAL COMPLIANCE – WAITING LIST CONTACT Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Eligibility and Special Provisions Criteria: Program procedures require sufficient documentation to demonstrate that waiting list selections and outreach were conducted consistently, timely, and in a transparent manner. Condition: For Section 8 project-specific vouchers, documentation of contact with individuals selected from the waiting list was not consistently maintained. Files lacked evidence of outreach such as letters, emails, call logs, or documentation of responses and outcomes. Cause: Documentation requirements for waiting list contact were not clearly defined or consistently enforced. Effect and Questioned Costs: Without documentation of outreach efforts, the program cannot demonstrate that project-specific voucher selections were conducted fairly and in compliance with program requirements, increasing risk of noncompliance or disputes. Recommendation: Management should implement a standardized process to document and retain all waiting list contact attempts, including method, dates, and outcomes, in project-specific voucher files. Management’s Response: When applicants call or come in to request a change to contact information, the PHA now requires the applicant to provide the updated information in writing (completed by the applicant) rather than staff updating records solely based on a verbal request. This provides documentation for the change and strengthens file integrity.
When applicants call or come in to request a change to contact information, the PHA now requires the applicant to provide the updated information in writing (completed by the applicant) rather than staff updating records solely based on a verbal request. This provides documentation for the change and strengthens file integrity.
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: Yes Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management’s Response: Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
Show full finding ▾Hide full finding ▴2024-001 FEDERAL COMPLIANCE – WAITING LIST PREFERENCES Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: According to 24 CFR 982.54(d), the PHA’s administrative plan must include procedures for the “Selection and admission of applicants from the PHA waiting list, including any PHA admission preferences, procedures for removing applicant names from the waiting list, and procedures for closing and reopening the PHA waiting list.” Condition: While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: Yes Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management’s Response: Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
2024-001
During our testing of compliance with Section 8 requirements, we noted several errors while reviewing 40 tenant files. These include the following: • One instance in which a tenant was accepted due to disabled status, but documentation of disability was not included in the tenant file. • One instance in which a tenant's utility allowance worksheet used the rates for the wrong bedroom size Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: Yes, 2024-002 Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management’s Response: Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.
Show full finding ▾Hide full finding ▴2025-002 FEDERAL COMPLIANCE – TENANT DOCUMENTATION Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Eligibility and Special Provisions Criteria: HUD requires Public Housing Authorities (PHA) to properly document the eligibility of tenants, properly calculate benefits based on tenant income and determine rent is reasonable. Condition: During our testing of compliance with Section 8 requirements, we noted several errors while reviewing 40 tenant files. These include the following: • One instance in which a tenant was accepted due to disabled status, but documentation of disability was not included in the tenant file. • One instance in which a tenant's utility allowance worksheet used the rates for the wrong bedroom size Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: Yes, 2024-002 Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management’s Response: Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.
Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.
2024-002
FAC accepted this audit on April 29, 2024 — management decision was due October 29, 2024.
While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: Yes Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management’s Response: Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
Show full finding ▾Hide full finding ▴2024-001 FEDERAL COMPLIANCE – WAITING LIST PREFERENCES Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: According to 24 CFR 982.54(d), the PHA’s administrative plan must include procedures for the “Selection and admission of applicants from the PHA waiting list, including any PHA admission preferences, procedures for removing applicant names from the waiting list, and procedures for closing and reopening the PHA waiting list.” Condition: While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: Yes Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management’s Response: Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
2023-005
During our testing of compliance with Section 8 requirements, we noted several errors while reviewing 40 tenant files. These include the following: • Three instances in which the income utilized to calculate benefits did not agree to documentation in the tenant file. • One instance in which a tenant was accepted due to homeless status, but documentation of homelessness was not included in the tenant file. • Rent Reasonableness Form with no conclusion as to whether rent was reasonable. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: Yes Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management’s Response: Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.
Show full finding ▾Hide full finding ▴2024-002 FEDERAL COMPLIANCE – TENANT DOCUMENTATION Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Eligibility and Special Provisions Criteria: HUD requires Public Housing Authorities (PHA) to properly document the eligibility of tenants, properly calculate benefits based on tenant income and determine rent is reasonable. Condition: During our testing of compliance with Section 8 requirements, we noted several errors while reviewing 40 tenant files. These include the following: • Three instances in which the income utilized to calculate benefits did not agree to documentation in the tenant file. • One instance in which a tenant was accepted due to homeless status, but documentation of homelessness was not included in the tenant file. • Rent Reasonableness Form with no conclusion as to whether rent was reasonable. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: Yes Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management’s Response: Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.
Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.
2023-003
We noted one instance after year-end in which a tenant was only given a 4-day notice before the effective date of a rent increase. Effect and Questioned Costs: Noncompliance with the Administrative Plan for the program. Repeat Finding: Yes Recommendation: We recommend that procedures be implemented to ensure tenants are given a 30-day notice prior to any rent increases that are result from an annual recertification. Management’s Response: Each caseworker has been issued an admin plan and refer to it often. Staff has been made aware that an increase in rent must be issued a 30 day notice. If the tenant rent decreases, the decrease is to take effect immediately. Administrator is also auditing files to help alleviate any errors.
Show full finding ▾Hide full finding ▴2024-003 FEDERAL COMPLIANCE – RENT INCREASE NOTICE Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: The City’s Administrative Plan requires that tenants be given a 30-day notice before the effective date of a rent increase that is based on the results of an annual recertification. Condition: We noted one instance after year-end in which a tenant was only given a 4-day notice before the effective date of a rent increase. Effect and Questioned Costs: Noncompliance with the Administrative Plan for the program. Repeat Finding: Yes Recommendation: We recommend that procedures be implemented to ensure tenants are given a 30-day notice prior to any rent increases that are result from an annual recertification. Management’s Response: Each caseworker has been issued an admin plan and refer to it often. Staff has been made aware that an increase in rent must be issued a 30 day notice. If the tenant rent decreases, the decrease is to take effect immediately. Administrator is also auditing files to help alleviate any errors.
Each caseworker has been issued an admin plan and refer to it often. Staff has been made aware that an increase in rent must be issued a 30 day notice. If the tenant rent decreases, the decrease is to take effect immediately. Administrator is also auditing files to help alleviate any errors.
2023-008
We noted that the utility rate data was analyzed and there was a more than 10 precent change for several categories. However, the utility allowance schedule was not updated during the year. Effect and Questioned Costs: Noncompliance with 24 CFR 982.517 Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to ensure that the utility allowance schedule is reviewed and updated annually as necessary with the change being approved by the Board of Commissioners. Management’s Response: Based on the review of utility rate data during FY24, the utility allowance schedule was updated and approved by the Board of Commissioners in February 2024.
Show full finding ▾Hide full finding ▴2024-004 FEDERAL COMPLIANCE – UTILITY ALLOWANCES Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: According to 24 CFR 982.517, the PHA must maintain an up-to-date utility schedule by annually reviewing utility rate data and adjusting its utility allowance schedule if there has been a rate change of 10 percent or more. Condition: We noted that the utility rate data was analyzed and there was a more than 10 precent change for several categories. However, the utility allowance schedule was not updated during the year. Effect and Questioned Costs: Noncompliance with 24 CFR 982.517 Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to ensure that the utility allowance schedule is reviewed and updated annually as necessary with the change being approved by the Board of Commissioners. Management’s Response: Based on the review of utility rate data during FY24, the utility allowance schedule was updated and approved by the Board of Commissioners in February 2024.
Based on the review of utility rate data during FY24, the utility allowance schedule was updated and approved by the Board of Commissioners in February 2024.
FAC accepted this audit on May 29, 2023 — management decision was due November 29, 2023.
During our review of the reports submitted for FY22, we noted that the reports excluded HAP expenses for project-based vouchers for January and February of 2022 totaling over $100,000. Effect and Questioned Costs: Inaccurate reporting in VMS could result in a negative effect on funding levels. Repeat Finding: No Recommendation: We recommend that procedures be implemented to ensure that accurate information is reported in VMS. Management?s Response: Prior to March 2022, reporting of Project Based Vouchers HAP payment amounts were not an option to input. This is a new field in the system. Administrator will ensure field will be reported for each month following February 2022.
Show full finding ▾Hide full finding ▴2022-001 FEDERAL COMPLIANCE ? VMS REPORTING Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development (?HUD?) Compliance Requirement: Reporting Criteria: All public housing agencies (?PHA?) are required to submit form HUD-52681-B, Voucher for Payment of Annual Contributions and Operating Statement, through the Voucher Management System (?VMS?) monthly. This information included on this form is utilized by HUD to determine funding levels. Condition: During our review of the reports submitted for FY22, we noted that the reports excluded HAP expenses for project-based vouchers for January and February of 2022 totaling over $100,000. Effect and Questioned Costs: Inaccurate reporting in VMS could result in a negative effect on funding levels. Repeat Finding: No Recommendation: We recommend that procedures be implemented to ensure that accurate information is reported in VMS. Management?s Response: Prior to March 2022, reporting of Project Based Vouchers HAP payment amounts were not an option to input. This is a new field in the system. Administrator will ensure field will be reported for each month following February 2022.
Prior to March 2022, reporting of Project Based Vouchers HAP payment amounts were not an option to input. This is a new field in the system. Administrator will ensure field will be reported for each month following February 2022.
During our audit, we noted that the PHA had over 50 submissions with errors and several dating back to the first few months of the fiscal year. Therefore, it appears that errors are not being resolved timely. Effect and Questioned Costs: Potentially incorrect information has been reported to HUD. Repeat Finding: No Recommendation: We recommend that procedures be implemented to ensure that submitted HUD-50058 forms with errors be resolved timely. Management?s Response: Administrator will timely upload any required data into PIC system moving forward. Staff will continue to correct any previously discovered errors while resolving any errors that may occur.
Show full finding ▾Hide full finding ▴2022-002 FEDERAL COMPLIANCE ? PIC ERRORS Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Reporting Criteria: The PHA is required to submit HUD-50058, Family Report, through HUD?s PIH Information Center (?PIC?) each time it completes an admission, annual reexamination, interim reexamination, portability move-in, termination of participation, portability move-out, or other change of unit for a family. When the information is uploaded, an error report is generated detailing any noted issues with the family information. The City is then required to correct the information to eliminate the errors. Condition: During our audit, we noted that the PHA had over 50 submissions with errors and several dating back to the first few months of the fiscal year. Therefore, it appears that errors are not being resolved timely. Effect and Questioned Costs: Potentially incorrect information has been reported to HUD. Repeat Finding: No Recommendation: We recommend that procedures be implemented to ensure that submitted HUD-50058 forms with errors be resolved timely. Management?s Response: Administrator will timely upload any required data into PIC system moving forward. Staff will continue to correct any previously discovered errors while resolving any errors that may occur.
Administrator will timely upload any required data into PIC system moving forward. Staff will continue to correct any previously discovered errors while resolving any errors that may occur.
During our testing of tenant files, we noted two instances in which the PHA was not able to provide the family application, income verification documentation, and executed lease and HAP contract. Additionally, we noted two instances in which the documentation for interim recertifications due to a loss of income was not included in the tenant files. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: No Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management?s Response: Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.
Show full finding ▾Hide full finding ▴2022-003 FEDERAL COMPLIANCE ? TENANT DOCUMENTATION Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Eligibility Criteria: 24 CFR ? 982.158 states "during the term of each assisted lease, and for at least three years thereafter, the PHA must keep (1) a copy of the executed lease; (2) the HAP contract; and (3) the application from the family. Condition: During our testing of tenant files, we noted two instances in which the PHA was not able to provide the family application, income verification documentation, and executed lease and HAP contract. Additionally, we noted two instances in which the documentation for interim recertifications due to a loss of income was not included in the tenant files. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: No Recommendation: We recommend that procedures be implemented to ensure that documentation is maintained in accordance with HUD requirements. Management?s Response: Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.
Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.
We noted that the PHA should have performed 13 quality control re-inspections, but only completed 12. However, 1 of those re-inspections was performed by the same individual performing the original inspection on the same day of the original inspection. Additionally, all of the re-inspections were completed for units at the Harbor Hill complex and, therefore, do not represent a cross section of neighborhoods. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: No Recommendation: We recommend that the PHA comply with quality control re-inspection requirements by calculating the appropriate sample size with the sample representing a cross section of neighborhoods and that the re-inspections be performed by someone other than the individual or completed the original inspection. Management?s Response: Quality Control inspections are currently being scheduled as per 24 CFR 982.2(b). Inspections will be performed on both Section 8 properties and Project Based properties. All QC inspections will be completed by Property Maintenance Manager.
Show full finding ▾Hide full finding ▴2022-004 FEDERAL COMPLIANCE ? QUALITY CONTROL INSPECTIONS Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: 24 CFR ? 982 includes requirements and guidelines for PHA?s to perform Housing Quality Standards (?HQS?) inspections for all housing units and quality control re-inspections for a sample of units every year. The sample size of units selected for quality control re-inspections are to be calculated in accordance 24 CFR ? 982.2(b). Condition: We noted that the PHA should have performed 13 quality control re-inspections, but only completed 12. However, 1 of those re-inspections was performed by the same individual performing the original inspection on the same day of the original inspection. Additionally, all of the re-inspections were completed for units at the Harbor Hill complex and, therefore, do not represent a cross section of neighborhoods. Effect and Questioned Costs: Noncompliance with HUD requirements. Repeat Finding: No Recommendation: We recommend that the PHA comply with quality control re-inspection requirements by calculating the appropriate sample size with the sample representing a cross section of neighborhoods and that the re-inspections be performed by someone other than the individual or completed the original inspection. Management?s Response: Quality Control inspections are currently being scheduled as per 24 CFR 982.2(b). Inspections will be performed on both Section 8 properties and Project Based properties. All QC inspections will be completed by Property Maintenance Manager.
Quality Control inspections are currently being scheduled as per 24 CFR 982.2(b). Inspections will be performed on both Section 8 properties and Project Based properties. All QC inspections will be completed by Property Maintenance Manager.
While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management?s Response: Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
Show full finding ▾Hide full finding ▴2022-005 FEDERAL COMPLIANCE ? WAITING LIST PREFERENCES Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: According to 24 CFR 982.54(d), the PHA?s administrative plan must include procedures for the ?Selection and admission of applicants from the PHA waiting list, including any PHA admission preferences, procedures for removing applicant names from the waiting list, and procedures for closing and reopening the PHA waiting list.? Condition: While reviewing applications for acceptance into the program, we noted several preference codes assigned to applicants that did not agree to information contained on the original application. Effect and Questioned Costs: Inadequate documentation of preference codes assigned to applicants. This could result in individuals improperly being moved to the top of the waiting list and allowed to enter the program before other qualified applicants. Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to document any changes to the original preference codes assigned to applicants. Management?s Response: Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
During our audit, we noted several check runs for the Section 8 program that did not include the finance department?s approval for payment. Additionally, we noted four checks that cleared for amounts other than the amount included on the check register, including two checks whose payee did not agree to the register, a check that was issued twice, and other checks that did not appear on the register. These errors caused increased difficulty in reconciling the bank statements in a timely manner. Additionally, we noted one instance where the direct deposit information for one landlord was entered incorrectly, which resulted in a payment of approximately $2,000 being sent to the wrong bank account. Cause: According to the PHA director, these differences were caused by the check registers being printed by program instead of check number. Therefore, the payment amount for several tenants for a certain check were listed in a separate section. Other errors were due to misfeeds in the check printer. Based on discussions with City management, the direct deposit error was a result of taking the change over the phone and not obtaining documentation of the correct checking account number. Effect and Questioned Costs: Reduced effectiveness of internal controls with the possibility of incorrect payments being processed. Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to ensure that checks written agree to the check register prior to mailing and the finance department approve all Section 8 check runs. These procedures should include printing the check register by check number and comparing the printed checks to the register prior to mailing. If any differences are noted due to misfeeds in the check printer, the register should be updated to reflect correct information. Furthermore, an updated check register should be provided to the finance department with a memorandum documenting the changes. The City may consider investing in printing equipment that allows check numbers to be printed on the checks instead of utilizing preprinted checks. Additionally, we recommend that all direct deposit changes be appropriately documented (i.e. cancelled check, deposit ticket, completed direct deposit form, etc.) from the landlord and be reviewed prior to processing the first payment. Management?s Response: Our agency is now printing check registers by check number which will alleviate the appearance of incorrect check amounts. We will be comparing checks to register prior to sending to finance for approval. Our staff will continue to confirm account numbers by using the direct deposit forms and canceled checks when available. We have started contacting finance prior to processing any Hold Harmless requests to ensure the original check hasn't cleared the bank before requesting a duplicate check.
Show full finding ▾Hide full finding ▴2022-006 FEDERAL COMPLIANCE - DISBURSEMENTS Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Allowable Costs Criteria: The City?s internal controls require that all disbursements be approved by the finance department prior to payment and that bank reconciliations be performed on all accounts. Condition: During our audit, we noted several check runs for the Section 8 program that did not include the finance department?s approval for payment. Additionally, we noted four checks that cleared for amounts other than the amount included on the check register, including two checks whose payee did not agree to the register, a check that was issued twice, and other checks that did not appear on the register. These errors caused increased difficulty in reconciling the bank statements in a timely manner. Additionally, we noted one instance where the direct deposit information for one landlord was entered incorrectly, which resulted in a payment of approximately $2,000 being sent to the wrong bank account. Cause: According to the PHA director, these differences were caused by the check registers being printed by program instead of check number. Therefore, the payment amount for several tenants for a certain check were listed in a separate section. Other errors were due to misfeeds in the check printer. Based on discussions with City management, the direct deposit error was a result of taking the change over the phone and not obtaining documentation of the correct checking account number. Effect and Questioned Costs: Reduced effectiveness of internal controls with the possibility of incorrect payments being processed. Repeat Finding: No Recommendation: We recommend that the PHA implement procedures to ensure that checks written agree to the check register prior to mailing and the finance department approve all Section 8 check runs. These procedures should include printing the check register by check number and comparing the printed checks to the register prior to mailing. If any differences are noted due to misfeeds in the check printer, the register should be updated to reflect correct information. Furthermore, an updated check register should be provided to the finance department with a memorandum documenting the changes. The City may consider investing in printing equipment that allows check numbers to be printed on the checks instead of utilizing preprinted checks. Additionally, we recommend that all direct deposit changes be appropriately documented (i.e. cancelled check, deposit ticket, completed direct deposit form, etc.) from the landlord and be reviewed prior to processing the first payment. Management?s Response: Our agency is now printing check registers by check number which will alleviate the appearance of incorrect check amounts. We will be comparing checks to register prior to sending to finance for approval. Our staff will continue to confirm account numbers by using the direct deposit forms and canceled checks when available. We have started contacting finance prior to processing any Hold Harmless requests to ensure the original check hasn't cleared the bank before requesting a duplicate check.
Our agency is now printing check registers by check number which will alleviate the appearance of incorrect check amounts. We will be comparing checks to register prior to sending to finance for approval. Our staff will continue to confirm account numbers by using the direct deposit forms and canceled checks when available. We have started contacting finance prior to processing any Hold Harmless requests to ensure the original check hasn't cleared the bank before requesting a duplicate check.
We noted overpayments to tenants and landlords totaling approximately $4,000 during FY22 with the errors carrying over to payments made during FY23. Cause: Through discussions with PHA management, it appears that these errors were due to incorrect effective dates being entered on form HUD-50058 during the recertification process. Currently, only new admissions are being subject to a supervisory review, while one is not being performed on interim and annual recertifications. Additionally, a Reconciliation Report is generated as part of the monthly check generation process that shows all changes that have been made to tenant information during the month. This report is not currently being reviewed. Effect and Questioned Costs: Incorrect amounts were paid to landlords and tenants. Repeat Finding: No Recommendation: We recommend that these overpayments be recouped from the landlords and tenants. Additionally, to prevent errors in the future, we recommend a supervisory review be performed on all interim and annual recertifications. Additionally, the ?Reconciliation Report? that is generated as part of the monthly check generation process should be reviewed to ensure all changes for the month are correct. Management?s Response: Each staff member has received training and has knowledge that effective dates for annual re-exams are to be for the 1st of the month Administrator is currently auditing all new admissions and random annual and interim reexaminations. Any errors found in this process are being corrected by caseworkers with Administrators help. Reconciliation report will be reviewed since audit. Funds have been recouped.
Show full finding ▾Hide full finding ▴2022-007 FEDERAL COMPLIANCE - OVERPAYMENTS Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Allowable Costs Criteria: 2 CFR Part 200, Subpart E requires direct costs charged to grant programs be specifically identified with a particular cost objective. Condition: We noted overpayments to tenants and landlords totaling approximately $4,000 during FY22 with the errors carrying over to payments made during FY23. Cause: Through discussions with PHA management, it appears that these errors were due to incorrect effective dates being entered on form HUD-50058 during the recertification process. Currently, only new admissions are being subject to a supervisory review, while one is not being performed on interim and annual recertifications. Additionally, a Reconciliation Report is generated as part of the monthly check generation process that shows all changes that have been made to tenant information during the month. This report is not currently being reviewed. Effect and Questioned Costs: Incorrect amounts were paid to landlords and tenants. Repeat Finding: No Recommendation: We recommend that these overpayments be recouped from the landlords and tenants. Additionally, to prevent errors in the future, we recommend a supervisory review be performed on all interim and annual recertifications. Additionally, the ?Reconciliation Report? that is generated as part of the monthly check generation process should be reviewed to ensure all changes for the month are correct. Management?s Response: Each staff member has received training and has knowledge that effective dates for annual re-exams are to be for the 1st of the month Administrator is currently auditing all new admissions and random annual and interim reexaminations. Any errors found in this process are being corrected by caseworkers with Administrators help. Reconciliation report will be reviewed since audit. Funds have been recouped.
Each staff member has received training and has knowledge that effective dates for annual re-exams are to be for the 1st of the month Administrator is currently auditing all new admissions and random annual and interim reexaminations. Any errors found in this process are being corrected by caseworkers with Administrators help. Reconciliation report will be reviewed since audit. Funds have been recouped.
We noted one instance after year-end in which a tenant was only given a 4-day notice before the effective date of a rent increase. Effect and Questioned Costs: Noncompliance with the Administrative Plan for the program. Repeat Finding: No Recommendation: We recommend that procedures be implemented to ensure tenants are given a 30-day notice prior to any rent increases that are result from an annual recertification. Management?s Response: Each caseworker has been issued an admin plan and refer to it often Staff has been made aware of increase in rent must be issued a 30 day notice If the tenant rent decreases, rent is to take effect immediately. Administrator is also auditing files to help alleviate any errors.
Show full finding ▾Hide full finding ▴2022-008 FEDERAL COMPLIANCE ? RENT INCREASE NOTICE Federal Program Name: Housing Choice Voucher Program Catalog of Federal Domestic Assistance Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions Criteria: The City?s Administrative Plan requires that tenants be given a 30-day notice before the effective date of a rent increase that is based on the results of an annual recertification. Condition: We noted one instance after year-end in which a tenant was only given a 4-day notice before the effective date of a rent increase. Effect and Questioned Costs: Noncompliance with the Administrative Plan for the program. Repeat Finding: No Recommendation: We recommend that procedures be implemented to ensure tenants are given a 30-day notice prior to any rent increases that are result from an annual recertification. Management?s Response: Each caseworker has been issued an admin plan and refer to it often Staff has been made aware of increase in rent must be issued a 30 day notice If the tenant rent decreases, rent is to take effect immediately. Administrator is also auditing files to help alleviate any errors.
Each caseworker has been issued an admin plan and refer to it often Staff has been made aware of increase in rent must be issued a 30 day notice If the tenant rent decreases, rent is to take effect immediately. Administrator is also auditing files to help alleviate any errors.
FAC accepted this audit on February 21, 2022 — management decision was due August 21, 2022.
During the 2021 fiscal year, a remote regulatory review was performed by the U.S. Department of Housing and Urban Development (HUD) that identified compliance issues. The following is a summary of noncompliance noted during the review and while performing our procedures: 1. A construction contract was executed prior to HUD approving the Request for Release of Funds (RROF). The contract was executed on December 13, 2019 and stated that payment thereunder was ?to be paid for by Community Development Block Grant (CDBG) Funds.? However, the RROF was not approved by HUD until January 31, 2020. 2. The environmental assessment for the Pollard Mills Infrastructure Project had several deficiencies that required correction. 3. Eligible individuals that received utility payments from CDBG-CV funds were not informed that if they received duplicated assistance, reimbursement of the benefits received would be required. 4. The addresses of two individuals who received boxed food purchased with CDBG-CV funds were not verified to ensure they resided in an area eligible to receive benefits. 5. Reporting under the Transparency Act for subawards that exceeded the $30,000 threshold was not completed. Cause: Procedures were not in place to ensure compliance with program requirements. Effect and Questioned Costs: Due to the non-compliance noted during the remote monitoring, the City was required to reimburse HUD for ineligible activities totaling $25,844.57. Repeat Finding: Repeat of 2020-001 Recommendation: We recommend that the program administrator, all program staff and a representative from the Finance department obtain extensive training on CDBG program requirements. Additionally, the City should implement adequate procedures to document compliance with CDBG national objectives.
Show full finding ▾Hide full finding ▴2021-001 FEDERAL COMPLIANCE - PROGRAM COMPLIANCE Federal Program Name: Community Development Block Grant (CDBG), Catalog of Federal Domestic Assistance Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Special Tests and Provisions and Reporting Criteria: 24 CFR 570.501(b) states that a recipient is responsible for ensuring that CDBG funds are used in accordance with all program requirements. Condition: During the 2021 fiscal year, a remote regulatory review was performed by the U.S. Department of Housing and Urban Development (HUD) that identified compliance issues. The following is a summary of noncompliance noted during the review and while performing our procedures: 1. A construction contract was executed prior to HUD approving the Request for Release of Funds (RROF). The contract was executed on December 13, 2019 and stated that payment thereunder was ?to be paid for by Community Development Block Grant (CDBG) Funds.? However, the RROF was not approved by HUD until January 31, 2020. 2. The environmental assessment for the Pollard Mills Infrastructure Project had several deficiencies that required correction. 3. Eligible individuals that received utility payments from CDBG-CV funds were not informed that if they received duplicated assistance, reimbursement of the benefits received would be required. 4. The addresses of two individuals who received boxed food purchased with CDBG-CV funds were not verified to ensure they resided in an area eligible to receive benefits. 5. Reporting under the Transparency Act for subawards that exceeded the $30,000 threshold was not completed. Cause: Procedures were not in place to ensure compliance with program requirements. Effect and Questioned Costs: Due to the non-compliance noted during the remote monitoring, the City was required to reimburse HUD for ineligible activities totaling $25,844.57. Repeat Finding: Repeat of 2020-001 Recommendation: We recommend that the program administrator, all program staff and a representative from the Finance department obtain extensive training on CDBG program requirements. Additionally, the City should implement adequate procedures to document compliance with CDBG national objectives.
Finding Number Planned Corrective Action Anticipated Completion Date Responsible Contact Person 2021-001 In response to the noted issues, the City will implement the following changes: ? The new Program and Grant Administrator will receive extensive training on environmental review procedures and will work closely with the Department of Housing and Urban Development?s regional environmental review officer, as well as Ashland?s certifying officer, to ensure compliance with all regulations. Additionally, the Program and Grant Administrator will review and update the project checklist containing the required steps of the environmental review, Request for Release of Funds, and the Authorization to Use Grant Funds. ? Guidance regarding duplication of services was established by HUD after the City had distributed applications for the utility assistance program, which has been discontinued. If the utility assistance program resumes, or if a similar program begins, the Program and Grant Administrator will ensure eligible individuals are informed of the requirement to reimburse duplicate assistance both verbally and in writing. ? The City of Ashland food box program has been discontinued. The City has established a contract with Ashland Community Kitchen to reimburse a food box program in the East Central CDBG target area. ? The new Program and Grant Administrator will receive extensive training regarding the Transparency Act for subawards exceeding the $30,000 threshold to ensure compliance with future programs. June 30, 2022 Chris Pullem, Community & Economic Development Director
2020-001
FAC accepted this audit on April 26, 2021 — management decision was due October 26, 2021.
During our review of CDBG program disbursements, we noted one instance where a construction contract was executed prior to HUD approving the Request for Release of Funds (RROF). The contract was executed on December 13, 2019 and stated that payment thereunder was ?to be paid for by Community Development Block Grant (CDBG) Funds.? However, the RROF was not approved by HUD until January 31, 2020. Criteria: In accordance with HUD?s environmental regulations in 24 CFR 58.22, a recipient may not commit HUD assistance under any program (such as the CDBG Program) listed in 24 CFR 58.1(b) on an activity or project until HUD has approved the recipient?s RROF. This prohibition extends to any non-HUD funds that may potentially be committed to the activity. Moreover, under the statute authorizing the CDBG Program, HUD may release funds for a project only if the RROF is submitted to HUD prior to any commitment of CDBG funds for the project (42 U.S.C. 5304(g)(2)). Cause: Procedures were not in place to ensure the RROF was approved by HUD prior to committing CDBG funds. Effect: Noncompliance with HUD environmental regulations. Recommendation: We recommend that the City implement procedures to ensure an environmental review and approved RROF have been obtained, when required, prior to committing HUD funds. Context: The amount identified as questioned costs represents the amount expended under the construction contract during the year. Questioned Costs: $128,647
Show full finding ▾Hide full finding ▴Federal Program Information: Community Development Block Grant (CDBG), Federal Catalog No. 14.218, U.S. Department of Housing and Urban Development (HUD). Condition: During our review of CDBG program disbursements, we noted one instance where a construction contract was executed prior to HUD approving the Request for Release of Funds (RROF). The contract was executed on December 13, 2019 and stated that payment thereunder was ?to be paid for by Community Development Block Grant (CDBG) Funds.? However, the RROF was not approved by HUD until January 31, 2020. Criteria: In accordance with HUD?s environmental regulations in 24 CFR 58.22, a recipient may not commit HUD assistance under any program (such as the CDBG Program) listed in 24 CFR 58.1(b) on an activity or project until HUD has approved the recipient?s RROF. This prohibition extends to any non-HUD funds that may potentially be committed to the activity. Moreover, under the statute authorizing the CDBG Program, HUD may release funds for a project only if the RROF is submitted to HUD prior to any commitment of CDBG funds for the project (42 U.S.C. 5304(g)(2)). Cause: Procedures were not in place to ensure the RROF was approved by HUD prior to committing CDBG funds. Effect: Noncompliance with HUD environmental regulations. Recommendation: We recommend that the City implement procedures to ensure an environmental review and approved RROF have been obtained, when required, prior to committing HUD funds. Context: The amount identified as questioned costs represents the amount expended under the construction contract during the year. Questioned Costs: $128,647
It is the City?s goal to ensure compliance with all federal regulations as outlined in Title 24 Part 58, Environmental Review Procedures for Entities Assuming HUD Environmental Responsibilities. To ensure the City?s compliance with HUD regulations going forward, we have developed and implemented the following policies, procedures, and best practices as they relate to the Environmental Review process. 1. All City staff associated with the execution of the CDBG Action Plan will participate in continued training on environmental review procedures, WISER (Web-Based Instructional System for Environmental Reviews) system, and lead-based paint hazards. 2. CDBG administrative staff and Certifying Officer will work closely with the Department of Housing & Urban Development Regional Environmental Review Officer and the City of Ashland Certifying Officer ensuring compliance with all regulations in relation to environmental review procedures. 3. The City of Ashland?s CDBG Grants Coordinator created a ?Project Checklist? which contains the required steps for Environmental Review, Request for Release of Funds, and Authorization to Use Grant Funds. 4. A completed checklist, along with the AUGF, will be submitted to the City?s CDBG Certifying Officer for review and approval prior to submission for approval of any associated contracts to the Ashland Board of City Commissioners. CDBG administrative staff will have the final responsibility to ensure no funds are expended on any project until appropriate HUD approval and release of funds approval are received. 5. The City of Ashland will implement the model HUD Environmental Review Handbook provided by Ramona. This will include policies and procedures, forms, resource materials, and model letters for our City.
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