MUNICIPALITY OF SAN JUANLocal Government

Section III – Federal Award Findings and Questioned Costs Assistance Listing No.: 17.258, 17.259, 17.278 WIOA Cluster Finding No. 2025-001 – Material Weakness on Internal Controls over Compliance and Compliance with Earmarking requirements Condition The Municipality uses ORACLE accounting system to keep financial information for all its operations and is required by the Puerto Rico Department of Economic Development and Commerce, the pass-through grantor agency, to use MIP accounting system to keep the financial information for the program. However, the Municipality has not been able to conclude a reconciliation of the financial transactions amongst both accounting records. As a result, the Municipality was not able to demonstrate, and we were not able to determine compliance with the earmarking requirements of the program using ORACLE. The Municipality meets the earmarking requirements when applied to the balances recorded in the MIP accounting system. Cause The Municipality has not established a formal reconciliation process to ensure that transactions recorded in ORACLE are in agreement with the transactions recorded in MIP. Effect Failure to reconcile the accounting systems increases the risk of noncompliance with the earmarking requirements which in turn may result in potential questioned costs, and the possibility of financial adjustments or sanctions from the Puerto Rico Department of Economic Development and Commerce and/or the federal grantor.

Finding No. 2022-001 Program: Section 8 Housing Choice Vouchers Assistance Listing No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2022 Compliance Requirement: Special Test - Housing Quality Standards Inspections-HQS Enforcement Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Compliance Requirements for units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family?s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: We were unable to observe the updated Housing Quality Standards (HQS) in 2 cases out of a selected sample of 40 cases. Cause: These situations occur because the internal control system of the Housing Authority of the Municipality of San Juan related to the requirements of Housing Quality Standards Inspections is not effectively identifying the regularity of the inspections. We were able to observe the Housing Quality Standards Inspections update for the following year. Effect: This situation has the effect of not meeting the Basic Housing Quality Standards (HQS) (24 CFR Part 982), which all units must meet before assistance can be paid on behalf of a family and at least annually during the term of the assisted lease. HQS defines "standard housing" and sets minimum criteria for the health and safety of program participants. Questioned Costs None Recommendation: Improves the planning of Housing Quality Standards Inspections to meet the due dates. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan

Findings and Questioned Costs - Major Federal Award Program Audit Department of Housing and Urban Development Finding No. 2022-001; Section 8, Assistance Listing 14.195 Criteria During the year ended June 30, 2022, the project paid management fees of $9,652 in excess of the amount approved by HUD. Condition Management fee payments are limited to the amounts determined in accordance with the terms of the management agreement. Cause Management pays fixed monthly fees and trues up these up at year-end to the amount allowed per the agreements with HUD. Due to the large vacancy amount at the project during the year ended June 30, 2022, the calculation resulted in an unusually large overpayment. Effect or Potential Effect The overpaid amount is an unauthorized distribution and therefore considered to be questioned costs. Questioned Costs $9,652 Recommendation The management company should reimburse the project for overpaid management fee in the amount of $9,652 and implement procedures to ensure that the management fee paid does not exceed the amount determined in accordance with the management agreement. Auditor Noncompliance Code: J - Unauthorized management fees Finding Resolution Status: Cleared Views of Responsible Officials In order to avoid any future overpayment management will proceed to calculate the fee based on the actual monthly collections instead of doing the reconciliation at year-end.

Program: Section 8 Housing Choice Vouchers Assistance Listing No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2022 Compliance Requirement: Eligibility - Form HUD-92006, Supplement to Application for Federally Assisted Housing. Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: Applicants must be provided the opportunity to complete the information on form HUD-92006, Supplement to Application for Federally Assisted Housing. The form gives applicants the option to identify an individual or organization that the O/A or PHA may contact and the reason(s) the individual or organization may be contacted. The applicants, if they choose to provide the additional contact information, must sign and date the form. Condition: We were able to observe 12 cases out of 40 cases in the selected sample where the HUD Form-92006, Supplement to Federally Assisted Housing Application could not be located. Cause: These situations occur because internal controls regarding the handling of documentation in the eligibility process are not effective as required by HUD compliance. We were able to observe for the subsequent year the use of this HUD-92006 form. Effect: Failure to provide information that facilitates the housing provider's contact with the person or organization identified by the tenant and that helps provide any special services or attention to the tenant and that may help resolve any tenancy issues that arise during the possession of said lessee. Questioned Costs None Recommendation: Improve documentation management processes when evaluating participants. Review and train program staff regarding necessary and HUD required documents. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan

Finding No. 2022-003 Program: Section 8 Project Based Cluster Assistance Listing No.: 14.182, 14.195, 14.249 & 14.856 Federal Agency: Department of Housing and Urban Development Award No.: RQ006SC0001, RQ006MR0001, RQ006MR0003 & RQ006MR0004 Federal Award Year: 2022 Compliance Requirement: Eligibility - Notice of Re-certification sent within 90 to 120 days. Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non- Compliance Criteria: Annual Re-certification [24 CFR sections 5.617, 880.603, 881.601, 882.515, 884.218, 886.124 y 886.324] Municipality of San Juan Housing Department Housing Authority of the Municipality of San Juan will maintain an automated re-certification tracking system and households will be notified by mail of the date and time for scheduled appointments a minimum of 90 days in advance of the anniversary date of their lease and Housing Assistance Payments contract. A listing of all required documentation necessary for the annual re-certification will be provided to the family with the notification of scheduled appointment. This information includes all documentation necessary to verify income, assets, allowances, and deductions along with any additions or deletions of household members. Condition: The Notice of Re-certification wasn?t observed in 1 case of a selected sample of 40 cases. Cause: This situation occurred because the Housing Department did not follow the required procedure as per the Code of Federal Regulations to notify the participants. Due to the backlog in the cases caused by the Covid-19 pandemic, they communicated directly by phone with the participants. Effect: If the family does not appear for the recertification interview, the caseworker may issue a notice of termination of assistance. Questioned Costs None Recommendation: The Housing Department should maintain and adopt a quality control review and checklist that includes all related documents and processes that must be completed for each participant. These procedures will help improve controls and documentation of participant eligibility and reduce the chance of noncompliance. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan

Finding No. 2022-001 Program: Section 8 Housing Choice Vouchers Assistance Listing No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2022 Compliance Requirement: Special Test - Housing Quality Standards Inspections-HQS Enforcement Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Compliance Requirements for units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family?s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). Condition: We were unable to observe the updated Housing Quality Standards (HQS) in 2 cases out of a selected sample of 40 cases. Cause: These situations occur because the internal control system of the Housing Authority of the Municipality of San Juan related to the requirements of Housing Quality Standards Inspections is not effectively identifying the regularity of the inspections. We were able to observe the Housing Quality Standards Inspections update for the following year. Effect: This situation has the effect of not meeting the Basic Housing Quality Standards (HQS) (24 CFR Part 982), which all units must meet before assistance can be paid on behalf of a family and at least annually during the term of the assisted lease. HQS defines "standard housing" and sets minimum criteria for the health and safety of program participants. Questioned Costs None Recommendation: Improves the planning of Housing Quality Standards Inspections to meet the due dates. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan

Findings and Questioned Costs - Major Federal Award Program Audit Department of Housing and Urban Development Finding No. 2022-001; Section 8, Assistance Listing 14.195 Criteria During the year ended June 30, 2022, the project paid management fees of $9,652 in excess of the amount approved by HUD. Condition Management fee payments are limited to the amounts determined in accordance with the terms of the management agreement. Cause Management pays fixed monthly fees and trues up these up at year-end to the amount allowed per the agreements with HUD. Due to the large vacancy amount at the project during the year ended June 30, 2022, the calculation resulted in an unusually large overpayment. Effect or Potential Effect The overpaid amount is an unauthorized distribution and therefore considered to be questioned costs. Questioned Costs $9,652 Recommendation The management company should reimburse the project for overpaid management fee in the amount of $9,652 and implement procedures to ensure that the management fee paid does not exceed the amount determined in accordance with the management agreement. Auditor Noncompliance Code: J - Unauthorized management fees Finding Resolution Status: Cleared Views of Responsible Officials In order to avoid any future overpayment management will proceed to calculate the fee based on the actual monthly collections instead of doing the reconciliation at year-end.

Program: Section 8 Housing Choice Vouchers Assistance Listing No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2022 Compliance Requirement: Eligibility - Form HUD-92006, Supplement to Application for Federally Assisted Housing. Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: Applicants must be provided the opportunity to complete the information on form HUD-92006, Supplement to Application for Federally Assisted Housing. The form gives applicants the option to identify an individual or organization that the O/A or PHA may contact and the reason(s) the individual or organization may be contacted. The applicants, if they choose to provide the additional contact information, must sign and date the form. Condition: We were able to observe 12 cases out of 40 cases in the selected sample where the HUD Form-92006, Supplement to Federally Assisted Housing Application could not be located. Cause: These situations occur because internal controls regarding the handling of documentation in the eligibility process are not effective as required by HUD compliance. We were able to observe for the subsequent year the use of this HUD-92006 form. Effect: Failure to provide information that facilitates the housing provider's contact with the person or organization identified by the tenant and that helps provide any special services or attention to the tenant and that may help resolve any tenancy issues that arise during the possession of said lessee. Questioned Costs None Recommendation: Improve documentation management processes when evaluating participants. Review and train program staff regarding necessary and HUD required documents. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan

Finding No. 2022-003 Program: Section 8 Project Based Cluster Assistance Listing No.: 14.182, 14.195, 14.249 & 14.856 Federal Agency: Department of Housing and Urban Development Award No.: RQ006SC0001, RQ006MR0001, RQ006MR0003 & RQ006MR0004 Federal Award Year: 2022 Compliance Requirement: Eligibility - Notice of Re-certification sent within 90 to 120 days. Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non- Compliance Criteria: Annual Re-certification [24 CFR sections 5.617, 880.603, 881.601, 882.515, 884.218, 886.124 y 886.324] Municipality of San Juan Housing Department Housing Authority of the Municipality of San Juan will maintain an automated re-certification tracking system and households will be notified by mail of the date and time for scheduled appointments a minimum of 90 days in advance of the anniversary date of their lease and Housing Assistance Payments contract. A listing of all required documentation necessary for the annual re-certification will be provided to the family with the notification of scheduled appointment. This information includes all documentation necessary to verify income, assets, allowances, and deductions along with any additions or deletions of household members. Condition: The Notice of Re-certification wasn?t observed in 1 case of a selected sample of 40 cases. Cause: This situation occurred because the Housing Department did not follow the required procedure as per the Code of Federal Regulations to notify the participants. Due to the backlog in the cases caused by the Covid-19 pandemic, they communicated directly by phone with the participants. Effect: If the family does not appear for the recertification interview, the caseworker may issue a notice of termination of assistance. Questioned Costs None Recommendation: The Housing Department should maintain and adopt a quality control review and checklist that includes all related documents and processes that must be completed for each participant. These procedures will help improve controls and documentation of participant eligibility and reduce the chance of noncompliance. Views of responsible officials: Management concurs with the finding. Isamar Pina Rivera Director of Housing Department Municipality of San Juan

Program: WIOA Cluster CFDA No.: 17.258, 17.259 & 17.278 Federal Agency: Department of Labor Pass-Through Entity: Commonwealth of Puerto Rico Right to Employment Administration Award No.: 2021-000060 & 2021-000061 Federal Award Year: 2021 Compliance Requirement: Eligibility Type of Finding: Significant deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria Federal regulations (CFR 982.401 (a) 982.405) require that participants between the ages of 18 and 26 need to be registered with the military service, Section 3 (50 USC App.453). Such registration is also required by section 189 (h), WIOA 113-128. Condition We found in one from the 40 files examined of the participant files that evidence of military registration had not been presented. Previously, by January 2021, the Puerto Rico Department of Economic Development and Commerce performed a monitoring procedure for fiscal years 2019-20 and 2020-21 and issued resolution number 8 where no evidence of military registration was also found. Cause These situations occur because the Municipality?s system of internal control relating to the compliance requirements is not effectively identifying and correcting these matters through the proper review of participant files for completeness of documents, signatures, and information, as well as for their accuracy. The current procedures do not effectively reduce the risk of ineligible participants receiving program benefits. Effect The continued failure to establish internal control over compliance with the above requirements exposes the Municipality to unauthorized uses or disposition of the program?s resources. Questioned Costs None Recommendation The Municipality should design and adopt a quality control review to assure that supporting documentation is kept in file. These procedures will help to improve controls and documentation concerning the eligibility of participants and will reduce the possibility of cost disallowances. Views of responsible officials Management concurs with the finding. Responsible Official Director of Federal Programs

Program: Section 8 Housing Choice Vouchers CFDA No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2021 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria The Request for Tenancy Approval (RFTA) is a required HUD form that the family provides to the owner. The owner completes it with information about the unit regarding unit size, rent, address, and utility responsibilities. The family returns it to Municipality. The RFTA provides Municipality with information necessary for the calculation of rent portions and the drafting of the Housing Assistance Payment Contract (HAP). The RFTA is not a lease; however, it?s required that a landlord complete the RFTA when he/she has determined he/she is willing to enter an assisted lease with the family. The participant submits the RFTA to Municipality staff who must determine affordability for the family and calculates HUD?s Rent Reasonableness of the unit cost. Rent Reasonableness requires staff being able to locate 3 comparable units of similar size, type and locations that have a gross rent (rent plus tenant paid utilities) that is equal to or greater than the rent requested. Condition We were not able to observe the RFTA in 6 cases and the comparable units in 10 cases of the 40 cases of the selected sample. Cause: This occurs because the Municipality does not maintain a proper filing system for the documents required by the CFR. Effect: The continued failure to establish internal control over compliance with the above requirements exposes the Municipality to unauthorized uses or disposition of the program?s resources. Questioned Costs Not determine Recommendation The Municipality should maintain and adopt a quality control revie and checklist that includes all related documents and processes that must be completed for each participant. These procedures will help improve controls and documentation of participant eligibility and reduce the chance of cost underwriting. Views of responsible officials Management concurs with the finding. Responsible Official Director of Federal Programs

Program: WIOA Cluster CFDA No.: 17.258, 17.259 & 17.278 Federal Agency: Department of Labor Pass-Through Entity: Commonwealth of Puerto Rico Right to Employment Administration Award No.: 2021-000060 & 2021-000061 Federal Award Year: 2021 Compliance Requirement: Eligibility Type of Finding: Significant deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria Federal regulations (CFR 982.401 (a) 982.405) require that participants between the ages of 18 and 26 need to be registered with the military service, Section 3 (50 USC App.453). Such registration is also required by section 189 (h), WIOA 113-128. Condition We found in one from the 40 files examined of the participant files that evidence of military registration had not been presented. Previously, by January 2021, the Puerto Rico Department of Economic Development and Commerce performed a monitoring procedure for fiscal years 2019-20 and 2020-21 and issued resolution number 8 where no evidence of military registration was also found. Cause These situations occur because the Municipality?s system of internal control relating to the compliance requirements is not effectively identifying and correcting these matters through the proper review of participant files for completeness of documents, signatures, and information, as well as for their accuracy. The current procedures do not effectively reduce the risk of ineligible participants receiving program benefits. Effect The continued failure to establish internal control over compliance with the above requirements exposes the Municipality to unauthorized uses or disposition of the program?s resources. Questioned Costs None Recommendation The Municipality should design and adopt a quality control review to assure that supporting documentation is kept in file. These procedures will help to improve controls and documentation concerning the eligibility of participants and will reduce the possibility of cost disallowances. Views of responsible officials Management concurs with the finding. Responsible Official Director of Federal Programs

Program: Section 8 Housing Choice Vouchers CFDA No.: 14.871 Federal Agency: Department of Housing and Urban Development Award No.: RQ006 Federal Award Year: 2021 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria The Request for Tenancy Approval (RFTA) is a required HUD form that the family provides to the owner. The owner completes it with information about the unit regarding unit size, rent, address, and utility responsibilities. The family returns it to Municipality. The RFTA provides Municipality with information necessary for the calculation of rent portions and the drafting of the Housing Assistance Payment Contract (HAP). The RFTA is not a lease; however, it?s required that a landlord complete the RFTA when he/she has determined he/she is willing to enter an assisted lease with the family. The participant submits the RFTA to Municipality staff who must determine affordability for the family and calculates HUD?s Rent Reasonableness of the unit cost. Rent Reasonableness requires staff being able to locate 3 comparable units of similar size, type and locations that have a gross rent (rent plus tenant paid utilities) that is equal to or greater than the rent requested. Condition We were not able to observe the RFTA in 6 cases and the comparable units in 10 cases of the 40 cases of the selected sample. Cause: This occurs because the Municipality does not maintain a proper filing system for the documents required by the CFR. Effect: The continued failure to establish internal control over compliance with the above requirements exposes the Municipality to unauthorized uses or disposition of the program?s resources. Questioned Costs Not determine Recommendation The Municipality should maintain and adopt a quality control revie and checklist that includes all related documents and processes that must be completed for each participant. These procedures will help improve controls and documentation of participant eligibility and reduce the chance of cost underwriting. Views of responsible officials Management concurs with the finding. Responsible Official Director of Federal Programs

Significant Deficiency on Community Services Block Grant Financing Reporting Federal Program Community Services Block Grant CFDA No. 93.569 Department of Health and Human Services Award Year and Number 2019-G994002 Pass-Through Entity Puerto Rico Office for Socioeconomic and Community Development Criteria All Community Services Block Grant (CSBG) grantees shall participate in a performance measurement system in accordance with Section 678E of the CSBG statute, which includes state-established performance standards and participation in a Result Oriented Management and Accountability-(ROMA) process or a comparable process approved by HHS. Grantees shall also prepare and submit an annual report on the measured performance of the State and the eligible entities within the State. The annual report submitted to the Office of Community Services contains accomplishments and results from the implementation of the plan submitted at the beginning of the fiscal year. Expenditure and program reports may be requested by the Office of Community Services as part of a monitoring review of eligible entities. Condition The primary recipient, Puerto Rico Office for Socioeconomic and Community Development (ODSEC, Spanish acronym) in Contract #2019-329283 and Memorandum # 2019-002 established program reports requirements. The Municipality submitted the CSBG Closing Report (CSBG-006) and First Quarterly Report (CSBG 3.0), 55 and 34 days after the due date, respectively. Cause The Municipality submitted on April 11, 2019, the CSBG Closing Report and the First Quarterly Report on February 28, 2019 that were due on January 15 and 24, 2019, respectively. Management informed us that the delay for these reports was because the person in-charge of program accounting and program financial reporting had recently passed away. Effect The Municipality was in noncompliance with the Financial Reporting submission which could decrease the funds received under CSBG program. Question Costs None. Recommendation We recommend that the Municipality establish an alternative procedure to assure the compliance with the report?s submission requirements. Responsible Official Director of Social and Community Development Management Response The Municipality immediately notified the granting agency of the challenges faced to complete the required reports and requested technical assistance to comply with the reporting requirements in a timely manner. As result, by the end of the fiscal year 2019, the program was able to comply with the reporting requirements and used the full grant allocation.

Significant Deficiency on Community Services Block Grant Financing Reporting Federal Program Community Services Block Grant CFDA No. 93.569 Department of Health and Human Services Award Year and Number 2019-G994002 Pass-Through Entity Puerto Rico Office for Socioeconomic and Community Development Criteria All Community Services Block Grant (CSBG) grantees shall participate in a performance measurement system in accordance with Section 678E of the CSBG statute, which includes state-established performance standards and participation in a Result Oriented Management and Accountability-(ROMA) process or a comparable process approved by HHS. Grantees shall also prepare and submit an annual report on the measured performance of the State and the eligible entities within the State. The annual report submitted to the Office of Community Services contains accomplishments and results from the implementation of the plan submitted at the beginning of the fiscal year. Expenditure and program reports may be requested by the Office of Community Services as part of a monitoring review of eligible entities. Condition The primary recipient, Puerto Rico Office for Socioeconomic and Community Development (ODSEC, Spanish acronym) in Contract #2019-329283 and Memorandum # 2019-002 established program reports requirements. The Municipality submitted the CSBG Closing Report (CSBG-006) and First Quarterly Report (CSBG 3.0), 55 and 34 days after the due date, respectively. Cause The Municipality submitted on April 11, 2019, the CSBG Closing Report and the First Quarterly Report on February 28, 2019 that were due on January 15 and 24, 2019, respectively. Management informed us that the delay for these reports was because the person in-charge of program accounting and program financial reporting had recently passed away. Effect The Municipality was in noncompliance with the Financial Reporting submission which could decrease the funds received under CSBG program. Question Costs None. Recommendation We recommend that the Municipality establish an alternative procedure to assure the compliance with the report?s submission requirements. Responsible Official Director of Social and Community Development Management Response The Municipality immediately notified the granting agency of the challenges faced to complete the required reports and requested technical assistance to comply with the reporting requirements in a timely manner. As result, by the end of the fiscal year 2019, the program was able to comply with the reporting requirements and used the full grant allocation.

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