AUTONOMOUS MUNICIPALITY OF PONCE

EIN: 660433627

UEI: JLHWBJJK69Y8

Data as of August 23, 2026

AUTONOMOUS MUNICIPALITY OF PONCE10 audit years36 findings22 repeat
10
Audit Years
36
Total Findings
22
Repeat Findings

FY 2023-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 6, 2024. 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 September 6, 2024 (716 days ago).

What is a management decision? →
2023-004
Reporting
MATERIAL WEAKNESSREPEAT

During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2023 was submitted late. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Cause of Condition The program staff faced performance challenges due to a lack of staff and this caused the accounting records to be delayed. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend the Municipality’s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None

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Federal Agency: U.S. Department of Housing and Urban Development: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Reporting – Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition: During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2023 was submitted late. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Cause of Condition The program staff faced performance challenges due to a lack of staff and this caused the accounting records to be delayed. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend the Municipality’s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None

Corrective Action Plan

The Federal Program Director has assigned additional trained personnel to ensure that financial reports required by the federal government are submitted on time. In addition, internal controls have been strengthened to ensure that reports are prepared correctly. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

Prior Finding References

2022-004

About Reporting →
2023-005
Eligibility

We performed an eligibility test and examined a sample of sixty (60) participant files. The following summarizes the deficiencies found: a) In six (6) cases, we found discrepancies between the income reported by participants in the HUD50058 – Family Report and record documentation. b) In one (1) case, we observed a variance between the standard payment amount that was applied and the amount that should have corresponded according to established guidelines. c) In one (1) case, a misstatement involving the standard payment number led to an alteration in the payment amount. Criteria 24 CFR section 982.516 (a) (2) states that the PHA must obtain and document in the tenant file third-party verification of the following factors, or document in the tenant file why third party verification was not available: (i) Reported family annual income; (ii) the value of assets; (iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income. Section 982.503 states that HUD publishes fair market rents for each market area in the U.S., requiring Public Housing Agencies (PHAs) to adopt a payment standard schedule based on these rents for different unit sizes within their jurisdiction. These payment standard amounts are used to calculate the monthly housing assistance payment for families, with a single payment standard amount established for each unit size, which can be uniform across the FMR area or vary by designated parts of the area. Cause of Condition The internal controls and procedures of the Municipality's program did not ensure that the data in HUD50058 - Family Report were correct. There was no internal control verifying income correctly. Effect of Condition The Municipality is not in compliance with 24 CFR Section 982.516 (A), Section 982.503 and with the PHA’s administrative plan. Recommendation We recommend that management improve monitoring procedures in internal controls and be able to accurately calculate the 50058-Family Report. Carefully check the file to verify what qualifies as income and what is not, as well as issues related to the payment standard. Questioned Costs None

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Federal Agency: U.S. Department of Housing and Urban Development: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Eligibility (E) Type of finding: Significant Deficiency in Internal Control (SD), Instance of Noncompliance (NC) Statement of Condition: We performed an eligibility test and examined a sample of sixty (60) participant files. The following summarizes the deficiencies found: a) In six (6) cases, we found discrepancies between the income reported by participants in the HUD50058 – Family Report and record documentation. b) In one (1) case, we observed a variance between the standard payment amount that was applied and the amount that should have corresponded according to established guidelines. c) In one (1) case, a misstatement involving the standard payment number led to an alteration in the payment amount. Criteria 24 CFR section 982.516 (a) (2) states that the PHA must obtain and document in the tenant file third-party verification of the following factors, or document in the tenant file why third party verification was not available: (i) Reported family annual income; (ii) the value of assets; (iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income. Section 982.503 states that HUD publishes fair market rents for each market area in the U.S., requiring Public Housing Agencies (PHAs) to adopt a payment standard schedule based on these rents for different unit sizes within their jurisdiction. These payment standard amounts are used to calculate the monthly housing assistance payment for families, with a single payment standard amount established for each unit size, which can be uniform across the FMR area or vary by designated parts of the area. Cause of Condition The internal controls and procedures of the Municipality's program did not ensure that the data in HUD50058 - Family Report were correct. There was no internal control verifying income correctly. Effect of Condition The Municipality is not in compliance with 24 CFR Section 982.516 (A), Section 982.503 and with the PHA’s administrative plan. Recommendation We recommend that management improve monitoring procedures in internal controls and be able to accurately calculate the 50058-Family Report. Carefully check the file to verify what qualifies as income and what is not, as well as issues related to the payment standard. Questioned Costs None

Corrective Action Plan

The Section 8 Program will improve its internal controls and monitoring procedures to assure the correction of income included in the 50058-Family Report. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

About Eligibility →
2023-006
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT

In our audit, we did not obtain evidence to validate the initial balances of HAP (Housing Assistance Payments) Equity and Administrative Fee Equity. From the account analysis, we found evidence that the current HAP and Administrative Fee Equity balances are accurate. However, we identified that the initial balances have not yet been subjected to an adequate analysis for a prior-year correction, and proper correction has not yet been implemented. Criteria 24 CFR 982.158 (a) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must bein the format required by HUD, including requirements governing computerized or electronic forms of record-keeping. Cause of Condition The Municipality's accountants failed to reconcile the prior year's HAP (Housing Assistance Payments) Equity and Administrative Fee Equity balances. Effect of Condition The Municipality did not have proper accounting records to allow them to maintain complete and accurate accounting records and detect errors in a timely manner. Recommendation We recommend that management reconcile the HAP (Housing Assistance Payments) Equity and Administrative Fee Equity balance and thoroughly document the process. Questioned Costs None

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Federal Agency: U.S. Department of Housing and Urban Development: Section 8 Housing Choice Vouchers (ALN 14.87 1) Compliance Requirement: Special Test – Rolling Forward Equity Balances Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition: In our audit, we did not obtain evidence to validate the initial balances of HAP (Housing Assistance Payments) Equity and Administrative Fee Equity. From the account analysis, we found evidence that the current HAP and Administrative Fee Equity balances are accurate. However, we identified that the initial balances have not yet been subjected to an adequate analysis for a prior-year correction, and proper correction has not yet been implemented. Criteria 24 CFR 982.158 (a) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must bein the format required by HUD, including requirements governing computerized or electronic forms of record-keeping. Cause of Condition The Municipality's accountants failed to reconcile the prior year's HAP (Housing Assistance Payments) Equity and Administrative Fee Equity balances. Effect of Condition The Municipality did not have proper accounting records to allow them to maintain complete and accurate accounting records and detect errors in a timely manner. Recommendation We recommend that management reconcile the HAP (Housing Assistance Payments) Equity and Administrative Fee Equity balance and thoroughly document the process. Questioned Costs None

Corrective Action Plan

As indicated in this finding, the auditors found evidence that the current HAP and Administrative Fee Equity balances are accurate. However, in order to realize the proper correction of prior-year balances, the Section Program Director and the Municipal Finance Office are evaluating the initial HAP and Administrative Fee Equity balances. Implementation Date: During the fiscal year 2022-2023 Responsible Persons: Mr. Job Bonilla Federal Program Director

Prior Finding References

2022-006

About Special Tests and Provisions →
2023-007
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT

During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2023 was submitted late. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Cause of Condition The program staff faced performance challenges due to lack of staff which caused the accounting records to be delayed. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend the Municipality’s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None

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Federal Agency: U.S. Department of Housing and Urban Development: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation (ALN 14.856) Compliance Requirement: Reporting – Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition: During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2023 was submitted late. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Cause of Condition The program staff faced performance challenges due to lack of staff which caused the accounting records to be delayed. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend the Municipality’s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None

Corrective Action Plan

As indicated for the finding 2023-004, the Federal Program Director has assigned additional trained personnel to ensure that the financial reports required by the federal government are submitted on time. In addition, internal controls have been strengthened to ensure that reports are prepared correctly. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

Prior Finding References

2022-007

About Special Tests and Provisions →

FY 2022-06-30

FAC accepted this audit on June 5, 2023 — management decision was due December 5, 2023.

2022-004
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2022-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2022 was not submitted. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Due to the COVID-19 Pandemic, a waiver was granted, extending the due date 60 more days (October 31, 2021) after fiscal year end. The FASS-PH system is one of HUD?s main monitoring and oversight system for the HCVP. Cause of Condition The program staff faced performance challenges due to the COVID-19 Pandemic, also the accounting records were delayed for such event. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend to the Municipality?s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None Prior-Year Finding This finding is similar to prior year finding 2021-005, 2020-009 and 2019-009. View of Responsible Official and Planned Corrective Action Plan As indicated to the finding 2022-002, the Municipality uses a mechanized accounting system (SIMA), which is also used by the Section 8 Program. The accounting system contains some reports that provide reliable financial data used to prepare the unaudited REAC Report. The Section 8 Program is taking corrective action measurements addressed to achieve the timely submission of GAAP-based unaudited financial data electronically to HUD. As a part of such measurements, a new accountant has been recruited by the Program, to who was assigned the responsibility of prepare and submit, on a timely basis, the required financial information, in accordance with the guides established by HUD. Also, the Central Accounting Department have established a working sheet to be used as model by the accountant to collect and organize financial information to be used in the preparation of required financial reports. Implementation Date March 31, 2024 Responsible Person Mr. Job Bonilla, Federal Program Director

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Finding Reference 2022-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2022 was not submitted. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Due to the COVID-19 Pandemic, a waiver was granted, extending the due date 60 more days (October 31, 2021) after fiscal year end. The FASS-PH system is one of HUD?s main monitoring and oversight system for the HCVP. Cause of Condition The program staff faced performance challenges due to the COVID-19 Pandemic, also the accounting records were delayed for such event. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend to the Municipality?s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None Prior-Year Finding This finding is similar to prior year finding 2021-005, 2020-009 and 2019-009. View of Responsible Official and Planned Corrective Action Plan As indicated to the finding 2022-002, the Municipality uses a mechanized accounting system (SIMA), which is also used by the Section 8 Program. The accounting system contains some reports that provide reliable financial data used to prepare the unaudited REAC Report. The Section 8 Program is taking corrective action measurements addressed to achieve the timely submission of GAAP-based unaudited financial data electronically to HUD. As a part of such measurements, a new accountant has been recruited by the Program, to who was assigned the responsibility of prepare and submit, on a timely basis, the required financial information, in accordance with the guides established by HUD. Also, the Central Accounting Department have established a working sheet to be used as model by the accountant to collect and organize financial information to be used in the preparation of required financial reports. Implementation Date March 31, 2024 Responsible Person Mr. Job Bonilla, Federal Program Director

Corrective Action Plan

As indicated to the finding 2022-002, the Municipality uses a mechanized accounting system (SIMA), which is also used by the Section 8 Program. The accounting system contains some reports that provide reliable financial data used to prepare the unaudited REAC Report. The Section 8 Program is taking corrective action measurements addressed to achieve the timely submission of GAAP-based unaudited financial data electronically to HUD. As a part of such measurements, a new accountant has been recruited by the Program, to who was assigned the responsibility of prepare and submit, on a timely basis, the required financial information, in accordance with the guides established by HUD. Also, the Central Accounting Department have established a working sheet to be used as model by the accountant to collect and organize financial information to be used in the preparation of required financial reports. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

Prior Finding References

2021-005

About Reporting →
2022-005
Reporting
MATERIAL WEAKNESS

Finding Reference 2022-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Accounting Records ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records for the Section 8 Housing Choice Vouchers to fairly present the financial position of the program and results of its operations. Criteria 24 CFR Subpart C, Part 85.20 (b) (2) states that the grantees and sub grantees must maintain records which adequately identify the source and application of funds, provided for financially-assisted activities. These records must contain information pertaining to grant or sub grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. 24 CFR Subpart D Section 982.158 (a) established that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms or record-keeping. The municipality must comply with the financial reporting requirements in 24 CFR part 5, subpart K. The financial management system of other grantees and sub-grantees must meet the following standards: ? Financial reporting: Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or sub-grant. ? Accounting records: Grantees and sub-grantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or sub-grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. Cause of Condition Adequate internal control and proper monitoring procedures do not exist to ensure the maintenance of complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program?s reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation Management should take necessary steps to establish and maintaining proper internal controls and periodic monitoring procedures to ensure the correct recognition of the Program?s financial and budgetary transactions in a complete set of accounting records, using the double-entry system. The Program must give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports to ascertain that: (1) the accounting system complies with state and federal laws, (2) all the transactions related to assets, liabilities, revenues and expenditures is recorded and reconciled in a timely manner. Questioned Costs None Prior-Year Finding This finding is similar to prior year finding 2020-008 and 2019-008. View of Responsible Official and Planned Corrective Action Plan The Department of Finance and Budget of the Municipality establish a new monitoring procedure for the preparation and authorization of journal entries to each transaction related to assets, liabilities, revenues and expenditures. Also, the Section 8 Program will give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports in order to make sure that the accounting system complies with state and federal laws. Implementation Date March 31, 2024 Responsible Person Mr. Job Bonilla, Federal Program Director

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Finding Reference 2022-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Accounting Records ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records for the Section 8 Housing Choice Vouchers to fairly present the financial position of the program and results of its operations. Criteria 24 CFR Subpart C, Part 85.20 (b) (2) states that the grantees and sub grantees must maintain records which adequately identify the source and application of funds, provided for financially-assisted activities. These records must contain information pertaining to grant or sub grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. 24 CFR Subpart D Section 982.158 (a) established that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms or record-keeping. The municipality must comply with the financial reporting requirements in 24 CFR part 5, subpart K. The financial management system of other grantees and sub-grantees must meet the following standards: ? Financial reporting: Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or sub-grant. ? Accounting records: Grantees and sub-grantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or sub-grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. Cause of Condition Adequate internal control and proper monitoring procedures do not exist to ensure the maintenance of complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program?s reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation Management should take necessary steps to establish and maintaining proper internal controls and periodic monitoring procedures to ensure the correct recognition of the Program?s financial and budgetary transactions in a complete set of accounting records, using the double-entry system. The Program must give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports to ascertain that: (1) the accounting system complies with state and federal laws, (2) all the transactions related to assets, liabilities, revenues and expenditures is recorded and reconciled in a timely manner. Questioned Costs None Prior-Year Finding This finding is similar to prior year finding 2020-008 and 2019-008. View of Responsible Official and Planned Corrective Action Plan The Department of Finance and Budget of the Municipality establish a new monitoring procedure for the preparation and authorization of journal entries to each transaction related to assets, liabilities, revenues and expenditures. Also, the Section 8 Program will give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports in order to make sure that the accounting system complies with state and federal laws. Implementation Date March 31, 2024 Responsible Person Mr. Job Bonilla, Federal Program Director

Corrective Action Plan

The Department of Finance and Budget of the Municipality establish a new monitoring procedure for the preparation and authorization of journal entries to each transaction related to assets, liabilities, revenues and expenditures. Also, the Section 8 Program will give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports in order to make sure that the accounting system complies with state and federal laws. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

About Reporting →
2022-006
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT

Finding Reference 2022-006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Special Test ? Rolling Forward Equity Balances Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition As part of our audit procedures over the monthly submitted reports, Voucher Management System (VMS), we required evidence of how the Administrative Fee Equity and HAP Equity were calculated. The accountant did not provide a monthly detail that reconciled with the information submitted in the VMS. In addition, the amounts presented in the VMS at June 30, 2022, do not reconcile with the amounts presented in the Financial Data Schedule (FDS). Criteria 24 CFR 982.158 (a) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be form required by HUD, including requirements governing computerized or electronic forms of record-keeping. The must comply with the financial reporting requirements in 24 CFR Part 5, Subpart H. Cause of Condition The program accountants do not reconcile the HAP and Administrative Fee Equity balances monthly. Effect of Condition The Municipality did not have proper accounting records to allow them maintain complete and accurate to detect and correct accounting errors in a timely manner. Recommendation We recommend management to prepare the bank conciliations timely, and reconcile on a monthly basis the HAP and Administrative Fee equity balances and document it. Questioned Costs None Prior-Year Finding This finding is similar to prior year finding 2021-007 and 2020-010. View of Responsible Official and Planned Corrective Action Plan Corrective action has been taken consisting in the timely preparation of the bank conciliations. However, the corrective actions needed to evidence the HAP and Administrative Fee equity balances calculation will be taken by the Municipal Finance Office and the Program Accountants. Also, adequate measurements addressed to reconcile the VMS with the Financial Data Schedule (FDS) will be taken. Implementation Date March 31, 2024 Responsible Person Mr. Job Bonilla, Federal Program Director

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Finding Reference 2022-006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Special Test ? Rolling Forward Equity Balances Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition As part of our audit procedures over the monthly submitted reports, Voucher Management System (VMS), we required evidence of how the Administrative Fee Equity and HAP Equity were calculated. The accountant did not provide a monthly detail that reconciled with the information submitted in the VMS. In addition, the amounts presented in the VMS at June 30, 2022, do not reconcile with the amounts presented in the Financial Data Schedule (FDS). Criteria 24 CFR 982.158 (a) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be form required by HUD, including requirements governing computerized or electronic forms of record-keeping. The must comply with the financial reporting requirements in 24 CFR Part 5, Subpart H. Cause of Condition The program accountants do not reconcile the HAP and Administrative Fee Equity balances monthly. Effect of Condition The Municipality did not have proper accounting records to allow them maintain complete and accurate to detect and correct accounting errors in a timely manner. Recommendation We recommend management to prepare the bank conciliations timely, and reconcile on a monthly basis the HAP and Administrative Fee equity balances and document it. Questioned Costs None Prior-Year Finding This finding is similar to prior year finding 2021-007 and 2020-010. View of Responsible Official and Planned Corrective Action Plan Corrective action has been taken consisting in the timely preparation of the bank conciliations. However, the corrective actions needed to evidence the HAP and Administrative Fee equity balances calculation will be taken by the Municipal Finance Office and the Program Accountants. Also, adequate measurements addressed to reconcile the VMS with the Financial Data Schedule (FDS) will be taken. Implementation Date March 31, 2024 Responsible Person Mr. Job Bonilla, Federal Program Director

Corrective Action Plan

Corrective action has been taken consisting in the timely preparation of the bank conciliations. However, the corrective actions needed to evidence the HAP and Administrative Fee equity balances calculation will be taken by the Municipal Finance Office and the Program Accountants. Also, adequate measurements addressed to reconcile the VMS with the Financial Data Schedule (FDS) will be taken. Implementation Date: During the fiscal year 2022-2023 Responsible Persons: Mr. Job Bonilla Federal Program Director

Prior Finding References

2021-007

About Special Tests and Provisions →
2022-007
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2022-007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation (ALN 14.856) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2022 was not submitted. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Due to the COVID-19 Pandemic, a waiver was granted, extending the due date 60 more days (October 31, 2021) after fiscal year end. The FASS-PH system is one of HUD?s main monitoring and oversight system for the HCVP. Cause of Condition The program staff faced performance challenges due to the COVID-19 Pandemic, also the accounting records were delayed for such event. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend to the Municipality?s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None Prior-Year Finding This finding is similar to prior year finding 2021-008, 2020-011 and 2019-010. View of Responsible Official and Planned Corrective Action Plan As indicated for the finding 2022-004, the Section 8 Program is taking corrective action measurements addressed to achieve the timely submission of GAAP-based unaudited financial data and audited financial information electronically to HUD. As a part of such measurements, a new accountant has been recruited by the Section 8 Program, to who was assigned the responsibility of prepare and submit, on a timely basis, the required financial information, in accordance with the guides established by HUD. The Central Accounting Department have established a work sheet to be used as model by the accountant to collect and organize financial information to be used in the preparation of required financial reports. Implementation Date March 31, 2024 Responsible Person Mr. Job Bonilla, Federal Program Director

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Finding Reference 2022-007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation (ALN 14.856) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2022 was not submitted. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Due to the COVID-19 Pandemic, a waiver was granted, extending the due date 60 more days (October 31, 2021) after fiscal year end. The FASS-PH system is one of HUD?s main monitoring and oversight system for the HCVP. Cause of Condition The program staff faced performance challenges due to the COVID-19 Pandemic, also the accounting records were delayed for such event. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend to the Municipality?s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None Prior-Year Finding This finding is similar to prior year finding 2021-008, 2020-011 and 2019-010. View of Responsible Official and Planned Corrective Action Plan As indicated for the finding 2022-004, the Section 8 Program is taking corrective action measurements addressed to achieve the timely submission of GAAP-based unaudited financial data and audited financial information electronically to HUD. As a part of such measurements, a new accountant has been recruited by the Section 8 Program, to who was assigned the responsibility of prepare and submit, on a timely basis, the required financial information, in accordance with the guides established by HUD. The Central Accounting Department have established a work sheet to be used as model by the accountant to collect and organize financial information to be used in the preparation of required financial reports. Implementation Date March 31, 2024 Responsible Person Mr. Job Bonilla, Federal Program Director

Corrective Action Plan

As indicated for the finding 2022-004, the Section 8 Program is taking corrective action measurements addressed to achieve the timely submission of GAAP-based unaudited financial data and audited financial information electronically to HUD. As a part of such measurements, a new accountant has been recruited by the Section 8 Program, to who was assigned the responsibility of prepare and submit, on a timely basis, the required financial information, in accordance with the guides established by HUD. The Central Accounting Department have established a work sheet to be used as model by the accountant to collect and organize financial information to be used in the preparation of required financial reports. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

Prior Finding References

2021-008

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2022-008
Other

Finding Reference 2022-008 Federal Agency: All Mayor Programs and Cluster Federal Program Title and ALN: Compliance Requirement: Single Audit Act Type of finding: Significant Deficiency in Internal Control (SD), Instance of Noncompliance (NC) Statement of Condition The Municipality did not submit, in a timely manner, to the Federal Audit Clearinghouse, the Single Audit Reporting package for the fiscal year ending on June 30, 2022. The due date for this report was no later than March 31, 2023. Criteria Uniform Guidance, Section 500.512, states that the audit must be completed, and the data collection form and reporting package must be submitted within of earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period. Cause of Condition The Municipality did not comply with the established regulation as prescribed in OMB Super Circular Uniform Guidance. Effect of Condition The Municipality could lose federal grants due to the noncompliance with the Single Audit Act requirements. Recommendation Procedures should be implemented to ensure that the Agency complies with the established Federal Regulation, as prescribed by OMB Super Circular Uniform Guidance. Questioned Costs None Prior-Year Finding No View of Responsible Official and Planned Corrective Action Plan The Finance and Budget Department will take the necessaries measurements to achieve that the single audit report of the fiscal year 2022-2023 be submitted to the Federal Audit Clearinghouse in a timely manner. Implementation Date March 31, 2024 Responsible Person Mrs. Damaris Suliveres, Finance and Budget Director

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Finding Reference 2022-008 Federal Agency: All Mayor Programs and Cluster Federal Program Title and ALN: Compliance Requirement: Single Audit Act Type of finding: Significant Deficiency in Internal Control (SD), Instance of Noncompliance (NC) Statement of Condition The Municipality did not submit, in a timely manner, to the Federal Audit Clearinghouse, the Single Audit Reporting package for the fiscal year ending on June 30, 2022. The due date for this report was no later than March 31, 2023. Criteria Uniform Guidance, Section 500.512, states that the audit must be completed, and the data collection form and reporting package must be submitted within of earlier of 30 calendar days after receipt of the auditor?s report, or nine months after the end of the audit period. Cause of Condition The Municipality did not comply with the established regulation as prescribed in OMB Super Circular Uniform Guidance. Effect of Condition The Municipality could lose federal grants due to the noncompliance with the Single Audit Act requirements. Recommendation Procedures should be implemented to ensure that the Agency complies with the established Federal Regulation, as prescribed by OMB Super Circular Uniform Guidance. Questioned Costs None Prior-Year Finding No View of Responsible Official and Planned Corrective Action Plan The Finance and Budget Department will take the necessaries measurements to achieve that the single audit report of the fiscal year 2022-2023 be submitted to the Federal Audit Clearinghouse in a timely manner. Implementation Date March 31, 2024 Responsible Person Mrs. Damaris Suliveres, Finance and Budget Director

Corrective Action Plan

The Finance and Budget Department will take the necessaries measurements to achieve that the single audit report of the fiscal year 2022-2023 be submitted to the Federal Audit Clearinghouse in a timely manner. Implementation Date: March 31, 2024 Responsible Persons: Mrs. Damaris Suliveres Finance and Budget Director

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FY 2021-06-30

FAC accepted this audit on August 25, 2022 — management decision was due February 25, 2023.

2021-005
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2021-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Community Development Block Grant Entitlement Grants (ALN 14.218) Compliance Requirement: Reporting ? Financial Administration (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding 2020-007, 2019-007 and 2018-009. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records that present the financial position of the program and results of its operations. Criteria 24 CFR 570.507 Subpart J Reports (d) Other reports. Recipients may be required to submit such other reports and information as HUD determines are necessary to carry out its responsibilities under the Act or other applicable laws. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation We recommend that management should strengthen it?s procedures an action to reconcile in a timely manner the federal funds reports with the accounting records in order to procedure reliable financial data. Questioned Costs None

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Finding Reference 2021-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Community Development Block Grant Entitlement Grants (ALN 14.218) Compliance Requirement: Reporting ? Financial Administration (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding 2020-007, 2019-007 and 2018-009. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records that present the financial position of the program and results of its operations. Criteria 24 CFR 570.507 Subpart J Reports (d) Other reports. Recipients may be required to submit such other reports and information as HUD determines are necessary to carry out its responsibilities under the Act or other applicable laws. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation We recommend that management should strengthen it?s procedures an action to reconcile in a timely manner the federal funds reports with the accounting records in order to procedure reliable financial data. Questioned Costs None

Corrective Action Plan

As indicated to the finding 2021-003, the Municipality has a financial and accounting system (SIMA), which permit to present the Municipality?s financial statements in the modified-accrual basis of accounting and to produce the government-wide financial statements. The financial and accounting system includes software applicable to federal programs. The implementation stage has not been completed. The Department of Finance and Budget has been restructured with suitable staff and adequate resources to achieve greater agility, efficiency and reliability in all processes related to income, purchases, disbursements, budget, property, accounting, bank reconciliations, insurances, among others. This result in better controls on budget and accounting processes. The Finance and Budget Director has established procedures to assure that all transactions be correctly accounted. However, additional necessaries procedures will be established to strengthen the accounting system. The Finance and Budget Director will establish quality control procedures to assure the correct preparation of journal entries and that all required transactions have been properly accounted for in the accounting system. Implementation Date: During the fiscal year 2022-2023 Responsible Persons: Mrs. Damaris Suliveres Finance and Budget Director

Prior Finding References

2020-007

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2021-006
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2021-006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2020-009 and 2019-009. Statement of Condition During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2021 was not submitted. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Due to the COVID-19 Pandemic, a waiver was granted, extending the due date 60 more days (October 31, 2021) after fiscal year end. The FASS-PH system is one of HUD?s main monitoring and oversight system for the HCVP. Cause of Condition The program staff faced performance challenges due to the COVID-19 Pandemic, also the accounting records were delayed for such event. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend to the Municipality?s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None

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Finding Reference 2021-006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2020-009 and 2019-009. Statement of Condition During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2021 was not submitted. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Due to the COVID-19 Pandemic, a waiver was granted, extending the due date 60 more days (October 31, 2021) after fiscal year end. The FASS-PH system is one of HUD?s main monitoring and oversight system for the HCVP. Cause of Condition The program staff faced performance challenges due to the COVID-19 Pandemic, also the accounting records were delayed for such event. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend to the Municipality?s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None

Corrective Action Plan

The Finance and Budget Department has designed worksheets, templates, and financial analysis necessaries to prepare and to submit to HUD the GAAP-based unaudited financial data required to be submitted electronically through the Real Estate Assessment Center (REAC). This information will be provided to a Section 8 Program accountant for use as a tool for the data collection and the preparation of annual reports required by HUD. Implementation Date: During the fiscal year 2022-2023 Responsible Persons: Mrs. Rosanel Velez Perazza Section 8 Accountant

Prior Finding References

2020-009

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2021-007
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT

Finding Reference 2021-007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Special Test ? Rolling Forward Equity Balances Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2020-010. Statement of Condition As part of our audit procedures over the monthly submitted reports, Voucher Management System (VMS), we required evidence of how the Administrative Fee Equity and HAP Equity were calculated. The accountant didn't provide a monthly detail that reconciled with the information submitted in the VMS. In addition, the amounts presented in the VMS at June 30, 2021, do not reconcile with the amounts presented in the Financial Data Schedule (FDS). Criteria 24 CFR 982.158 (a) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be form required by HUD, including requirements governing computerized or electronic forms of record-keeping. The must comply with the financial reporting requirements in 24 CFR Part 5, Subpart H. Cause of Condition The program accountants do not reconcile the HAP and Administrative Fee Equity balances monthly. Effect of Condition The Municipality did not have proper accounting records to allow them maintain complete and accurate to detect and correct accounting errors in a timely manner. Recommendation We recommend management to prepare the bank conciliations timely, and reconcile on a monthly basis the HAP and Administrative Fee equity balances and document it. Questioned Costs None

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Finding Reference 2021-007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Section 8 Housing Choice Vouchers (ALN 14.871) Compliance Requirement: Special Test ? Rolling Forward Equity Balances Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2020-010. Statement of Condition As part of our audit procedures over the monthly submitted reports, Voucher Management System (VMS), we required evidence of how the Administrative Fee Equity and HAP Equity were calculated. The accountant didn't provide a monthly detail that reconciled with the information submitted in the VMS. In addition, the amounts presented in the VMS at June 30, 2021, do not reconcile with the amounts presented in the Financial Data Schedule (FDS). Criteria 24 CFR 982.158 (a) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be form required by HUD, including requirements governing computerized or electronic forms of record-keeping. The must comply with the financial reporting requirements in 24 CFR Part 5, Subpart H. Cause of Condition The program accountants do not reconcile the HAP and Administrative Fee Equity balances monthly. Effect of Condition The Municipality did not have proper accounting records to allow them maintain complete and accurate to detect and correct accounting errors in a timely manner. Recommendation We recommend management to prepare the bank conciliations timely, and reconcile on a monthly basis the HAP and Administrative Fee equity balances and document it. Questioned Costs None

Corrective Action Plan

Internal control procedures will be design by the Financial and Budget Department related to the monthly reconciliation and documentation of the HAP and Administrative Fee equity balances included in the Voucher Management System (VMS) Reports submitted to HUD. Implementation Date: During the fiscal year 2022-2023 Responsible Persons: Mrs. Rosanel Velez Perazza Section 8 Accountant

Prior Finding References

2020-010

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2021-008
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2021-008 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation (ALN 14.856) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2020-011 and 2019-010. Statement of Condition During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2021 was not submitted. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Due to the COVID-19 Pandemic, a waiver was granted, extending the due date 60 more days (October 31, 2021) after fiscal year end. The FASS-PH system is one of HUD?s main monitoring and oversight system for the HCVP. Cause of Condition The program staff faced performance challenges due to the COVID-19 Pandemic, also the accounting records were delayed for such event. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend to the Municipality?s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None

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Finding Reference 2021-008 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and ALN: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation (ALN 14.856) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2020-011 and 2019-010. Statement of Condition During our audit procedures over the reporting of FASS-PH System, we noted that the Unaudited REAC report for fiscal year June 30, 2021 was not submitted. Criteria Financial Assessment Sub-system, FASS-PH. The Uniform Financial Reporting Standards (24 CFR section 5.801) require PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD. The Uniform Financial Reporting Standards requires PHA to submit the Unaudited REAC 60 days after fiscal year end. Due to the COVID-19 Pandemic, a waiver was granted, extending the due date 60 more days (October 31, 2021) after fiscal year end. The FASS-PH system is one of HUD?s main monitoring and oversight system for the HCVP. Cause of Condition The program staff faced performance challenges due to the COVID-19 Pandemic, also the accounting records were delayed for such event. Effect of Condition The Municipality failed to submit the required REAC report within the 60 calendar days required by the regulation, which leads to the noncompliance of the reporting requirement. Recommendation We recommend to the Municipality?s management to implement proper internal controls in order to ascertain that the reports are submitted timely. Questioned Costs None

Corrective Action Plan

As indicated to the finding 2021-006, the Finance and Budget Department has designed worksheets, templates, and financial analysis necessaries to prepare and submit to HUD the GAAP-based unaudited financial data required to be submitted electronically through the Real Estate Assessment Center (REAC). This information will be provided to a Section 8 Program accountant for use as a tool for the data collection and the preparation of annual reports required by HUD. Implementation Date: During the fiscal year 2022-2023 Responsible Persons: Mrs. Rosanel Velez Perazza Section 8 Accountant

Prior Finding References

2020-011

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FY 2020-06-30

FAC accepted this audit on May 27, 2021 — management decision was due November 27, 2021.

2020-007
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2020-007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CDBG ? Entitlement Grants Cluster; Community Development Block Grant-Entitlement CFDA Number: Program (CFDA No. 14.218); Compliance Requirement: Reporting ? Financial Administration (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding 2019-007 and 2018-009. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records that present the financial position of the program and results of its operations. Criteria 24 CFR 570.507 Subpart J Reports (d) Other reports. Recipients may be required to submit such other reports and information as HUD determines are necessary to carry out its responsibilities under the Act or other applicable laws. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation We recommend that management should strengthen it?s procedures an action to reconcile in a timely manner the federal funds reports with the accounting records in order to procedure reliable financial data. Questioned Costs None

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Finding Reference 2020-007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CDBG ? Entitlement Grants Cluster; Community Development Block Grant-Entitlement CFDA Number: Program (CFDA No. 14.218); Compliance Requirement: Reporting ? Financial Administration (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding 2019-007 and 2018-009. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records that present the financial position of the program and results of its operations. Criteria 24 CFR 570.507 Subpart J Reports (d) Other reports. Recipients may be required to submit such other reports and information as HUD determines are necessary to carry out its responsibilities under the Act or other applicable laws. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation We recommend that management should strengthen it?s procedures an action to reconcile in a timely manner the federal funds reports with the accounting records in order to procedure reliable financial data. Questioned Costs None

Corrective Action Plan

As indicated in the finding 2020-003, the program?s management has an accounting program (SIMA), which contains adequate procedures for the timely conciliation of federal funds reporting with accounting records and to produce reliable financial data. Accounting personnel assigned to the Finance and Budget Department will visit the program accountants to determine the adequate of the accounting process, in order to determine if reliable financial data is produced of such process. Also, the Chief Financial Officer will discuss the recommendation included in this finding with the Program?s Management in order to ensure its complete implementation. A follow-up procedure will be established until the corrective action has been completed. Implementation Date: During the 2020-2021 fiscal year Responsible Persons: Mrs. Damaris Suliveres, Finance and Budget Director

Prior Finding References

2019-007

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2020-008
Reporting
MATERIAL WEAKNESSREPEATQUESTIONED COSTS

Finding Reference 2020-008 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Reporting ? Accounting Records (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2019-008, 2018-012 and 2017-007. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records for the Section 8 Housing Choice Vouchers to fairly present the financial position of the program and results of its operations. The financial information reported in Voucher Management System (VMS) is based on accounting information compiled from different sources and not from a complete set of accounting records. Criteria 24 CFR Subpart C, Part 85.20 (b) (2) states that the grantees and sub grantees must maintain records which adequately identify the source and application of funds, provided for financially-assisted activities. These records must contain information pertaining to grant or sub grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. 24 CFR Subpart D Section 982.158 (a), established that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms or record-keeping. The municipality must comply with the financial reporting requirements in 24 CFR part 5, subpart K. The financial management system of other grantees and sub-grantees must meet the following standards: ? Financial reporting: Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or sub-grant. ? Accounting records: Grantees and sub-grantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or sub-grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation Management should take necessary steps to establish and maintaining proper internal controls and periodic monitoring procedures to ensure the correct recognition of the Program?s financial and budgetary transactions in a complete set of accounting records, using the double-entry system. The Program must give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports to ascertain that: (1) the accounting system complies with state and federal laws, (2) all the transactions related to assets, liabilities, revenues and expenditures is recorded and reconciled in a timely manner. Questioned Costs None

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Finding Reference 2020-008 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Reporting ? Accounting Records (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2019-008, 2018-012 and 2017-007. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records for the Section 8 Housing Choice Vouchers to fairly present the financial position of the program and results of its operations. The financial information reported in Voucher Management System (VMS) is based on accounting information compiled from different sources and not from a complete set of accounting records. Criteria 24 CFR Subpart C, Part 85.20 (b) (2) states that the grantees and sub grantees must maintain records which adequately identify the source and application of funds, provided for financially-assisted activities. These records must contain information pertaining to grant or sub grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. 24 CFR Subpart D Section 982.158 (a), established that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms or record-keeping. The municipality must comply with the financial reporting requirements in 24 CFR part 5, subpart K. The financial management system of other grantees and sub-grantees must meet the following standards: ? Financial reporting: Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or sub-grant. ? Accounting records: Grantees and sub-grantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or sub-grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation Management should take necessary steps to establish and maintaining proper internal controls and periodic monitoring procedures to ensure the correct recognition of the Program?s financial and budgetary transactions in a complete set of accounting records, using the double-entry system. The Program must give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports to ascertain that: (1) the accounting system complies with state and federal laws, (2) all the transactions related to assets, liabilities, revenues and expenditures is recorded and reconciled in a timely manner. Questioned Costs None

Corrective Action Plan

As indicated in the finding 2020-007, accounting personnel assigned to the Finance and Budget Department will visit the program accountants to determine the adequate of the accounting process, in order to determine if reliable financial data is produced of such process. Implementation Date: During the 2021-2022 fiscal year Responsible Persons: Mrs. Damaris Suliveres, Finance and Budget Director

Prior Finding References

2019-008

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2020-009
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2020-009 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2019-009. Statement of Condition We performed a Reporting Test and did not find evidence that GAAP-based unaudited financial data was submitted electronically to HUD for the fiscal year 2019-2020. Criteria OMB No. 2535-0107, 24 CFR Section 5.801, requires PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD trough the Real Estate Assessment Center (REAC). The FASS-PH system is one of HUD?s main monitoring and oversight systems for the HCVP. Cause of Condition The Municipality did not maintain evidence of the Real Estate Assessment Center (REAC) audited information submission for the fiscal year 2019-2020. Effect of Condition The PHA did not comply with the OMB No. 2535-0107, 24 CFR Section 5.801. Recommendation We recommend to the Municipality?s management to instruct the program accountant to submit timely GAAP-based unaudited and audited financial information electronically to HUD. Questioned Costs None

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Finding Reference 2020-009 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2019-009. Statement of Condition We performed a Reporting Test and did not find evidence that GAAP-based unaudited financial data was submitted electronically to HUD for the fiscal year 2019-2020. Criteria OMB No. 2535-0107, 24 CFR Section 5.801, requires PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD trough the Real Estate Assessment Center (REAC). The FASS-PH system is one of HUD?s main monitoring and oversight systems for the HCVP. Cause of Condition The Municipality did not maintain evidence of the Real Estate Assessment Center (REAC) audited information submission for the fiscal year 2019-2020. Effect of Condition The PHA did not comply with the OMB No. 2535-0107, 24 CFR Section 5.801. Recommendation We recommend to the Municipality?s management to instruct the program accountant to submit timely GAAP-based unaudited and audited financial information electronically to HUD. Questioned Costs None

Corrective Action Plan

Accounting personnel assigned to the Finance and Budget Department will visit the program accountants to determine the adequate of the accounting process, in order to determine if reliable financial data is produced of such process. Emphasis will be given to the established internal controls procedures related to record keeping and adjustments in order to ensure compliance with the federal reporting requirements. . Implementation Date: During the 2021-2022 fiscal year Responsible Persons: Mrs. Ana Rita Hernandez, Section 8 Accountant

Prior Finding References

2019-009

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2020-010
Special Tests & Provisions
MATERIAL WEAKNESS

Finding Reference 2020-010 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Special Test ? Rolling Forward Equity Balances Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition As part of our audit procedures over the monthly submitted reports, Voucher Management System (VMS), we required evidence of how the Administrative Fee Equity and HAP Equity were calculated. The accountant didn't provide a monthly detail that reconciled with the information submitted in the VMS. In addition, the amounts presented in the VMS at June 30, 2020, do not reconcile with the amounts presented in the Financial Data Schedule (FDS). Criteria 24 CFR 982.158 (a) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be form required by HUD, including requirements governing computerized or electronic forms of record-keeping. The must comply with the financial reporting requirements in 24 CFR Part 5, Subpart H. Cause of Condition The program accountants do not reconcile the HAP and Administrative Fee Equity balances monthly. Effect of Condition The Municipality did not have proper accounting records to allow them maintain complete and accurate to detect and correct accounting errors in a timely manner. Recommendation We recommend management to prepare the bank conciliations timely, and reconcile on a monthly basis the HAP and Administrative Fee equity balances and document it. Questioned Costs None

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Finding Reference 2020-010 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Special Test ? Rolling Forward Equity Balances Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition As part of our audit procedures over the monthly submitted reports, Voucher Management System (VMS), we required evidence of how the Administrative Fee Equity and HAP Equity were calculated. The accountant didn't provide a monthly detail that reconciled with the information submitted in the VMS. In addition, the amounts presented in the VMS at June 30, 2020, do not reconcile with the amounts presented in the Financial Data Schedule (FDS). Criteria 24 CFR 982.158 (a) states that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be form required by HUD, including requirements governing computerized or electronic forms of record-keeping. The must comply with the financial reporting requirements in 24 CFR Part 5, Subpart H. Cause of Condition The program accountants do not reconcile the HAP and Administrative Fee Equity balances monthly. Effect of Condition The Municipality did not have proper accounting records to allow them maintain complete and accurate to detect and correct accounting errors in a timely manner. Recommendation We recommend management to prepare the bank conciliations timely, and reconcile on a monthly basis the HAP and Administrative Fee equity balances and document it. Questioned Costs None

Corrective Action Plan

Accounting personnel assigned to the Finance and Budget Department will visit the program accountants to determine the adequate of the accounting process, in order to determine if reliable financial data is produced of such process. Emphasis will be given to the established internal controls procedures related to record keeping and adjustments in order to ensure compliance with the federal reporting requirements. As part of the evaluation the accountants will examine the adequacy of financial records used to prepare monthly reports submitted through the Voucher Management System (VMS). Implementation Date: During the 2021-2022 fiscal year Responsible Persons: Mrs. Ana Rita Hernandez, Section 8 Accountant

About Special Tests and Provisions →
2020-011
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2020-011 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation (CFDA No. 14.856) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2019-010. Statement of Condition We performed a Reporting Test and did not find evidence that GAAP-based unaudited financial data was submitted electronically to HUD for the fiscal year 2019-2020. Criteria OMB No. 2535-0107, 24 CFR Section 5.801, requires PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD trough the Real Estate Assessment Center (REAC). The FASS-PH system is one of HUD?s main monitoring and oversight systems for the HCVP. Cause of Condition The Municipality did not maintain evidence of the Real Estate Assessment Center (REAC) audited information submission for the fiscal year 2019-2020. Effect of Condition The PHA did not comply with the OMB No. 2535-0107, 24 CFR Section 5.801. Recommendation We recommend to the Municipality?s management to instruct the program accountant to submit timely GAAP-based unaudited and audited financial information electronically to HUD. Questioned Costs None

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Finding Reference 2020-011 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation (CFDA No. 14.856) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2019-010. Statement of Condition We performed a Reporting Test and did not find evidence that GAAP-based unaudited financial data was submitted electronically to HUD for the fiscal year 2019-2020. Criteria OMB No. 2535-0107, 24 CFR Section 5.801, requires PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD trough the Real Estate Assessment Center (REAC). The FASS-PH system is one of HUD?s main monitoring and oversight systems for the HCVP. Cause of Condition The Municipality did not maintain evidence of the Real Estate Assessment Center (REAC) audited information submission for the fiscal year 2019-2020. Effect of Condition The PHA did not comply with the OMB No. 2535-0107, 24 CFR Section 5.801. Recommendation We recommend to the Municipality?s management to instruct the program accountant to submit timely GAAP-based unaudited and audited financial information electronically to HUD. Questioned Costs None

Corrective Action Plan

Accounting personnel assigned to the Finance and Budget Department will visit the program accountants to determine the adequate of the accounting process, in order to determine if reliable financial data is produced of such process. Emphasis will be given to the established internal controls procedures related to record keeping and adjustments in order to ensure compliance with the federal reporting requirements. As part of the evaluation the accountants will examine the adequacy of financial records used to prepare monthly reports submitted electronically to HUD. Implementation Date: During the 2021-2022 fiscal year Responsible Persons: Mrs. Ana Rita Hernandez, Section 8 Accountant

Prior Finding References

2019-010

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2020-012
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2020-012 Federal Agency: U.S. Department of Health and Human Services Federal Program Title and CFDA Number: Head Start Program (CFDA No. 93.600) Compliance Requirement: Reporting ? Financial Administration Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2019-011, 2018-013 and 2016-009. Statement of Condition The financial information reported in the financial reporting is based on accounting information compiled from different sources and not from a complete set of accounting records, resulting in errors in the amounts reported in the Federal Financial Report (Standard Form 425) submitted during program year. As an alternate procedure, we compared the amounts reported as federal expenditures in the monthly Financial Reports and the amounts detailed in the supporting accounting documentation used for the preparation of these reports and there were significant differences between the amounts reported and the ones detailed in such documentation. Criteria The OMB Common Rules, Subpart C, Section .20 (b) (1), states that the grantee must maintain internal control procedures that permits proper tracing of funds to the accounting records. Also, it requires accurate, current and complete disclosure of financial results. Cause of Condition Adequate internal controls do not exist to ensure the correctness of the quarterly reports submitted to the federal agency. Also, proper monitoring procedures do not exist for the information reported in the Federal Financial Report (SF-425). Effect of Condition The Program is not in compliance with the Common Rules, Subpart C, Section .20 (b) (1). Recommendation We recommend the Program establishes monitoring procedures to ensure the accuracy and completeness of accounting records and correct preparation and submission of the monthly financial reports. Questioned Costs None

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Finding Reference 2020-012 Federal Agency: U.S. Department of Health and Human Services Federal Program Title and CFDA Number: Head Start Program (CFDA No. 93.600) Compliance Requirement: Reporting ? Financial Administration Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2019-011, 2018-013 and 2016-009. Statement of Condition The financial information reported in the financial reporting is based on accounting information compiled from different sources and not from a complete set of accounting records, resulting in errors in the amounts reported in the Federal Financial Report (Standard Form 425) submitted during program year. As an alternate procedure, we compared the amounts reported as federal expenditures in the monthly Financial Reports and the amounts detailed in the supporting accounting documentation used for the preparation of these reports and there were significant differences between the amounts reported and the ones detailed in such documentation. Criteria The OMB Common Rules, Subpart C, Section .20 (b) (1), states that the grantee must maintain internal control procedures that permits proper tracing of funds to the accounting records. Also, it requires accurate, current and complete disclosure of financial results. Cause of Condition Adequate internal controls do not exist to ensure the correctness of the quarterly reports submitted to the federal agency. Also, proper monitoring procedures do not exist for the information reported in the Federal Financial Report (SF-425). Effect of Condition The Program is not in compliance with the Common Rules, Subpart C, Section .20 (b) (1). Recommendation We recommend the Program establishes monitoring procedures to ensure the accuracy and completeness of accounting records and correct preparation and submission of the monthly financial reports. Questioned Costs None

Corrective Action Plan

As recommended the Head Start Program will establishes monitoring procedures to ensure the accuracy and completeness of accounting records and correct preparation and submission of the monthly financial reports. Implementation Date: During the 2021-2022 fiscal year Responsible Persons: Mrs. Angie Torres, Head Start Program Director Mr. Amarelys Berrios, Head Start Fiscal Officer

Prior Finding References

2019-011

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FY 2019-06-30

FAC accepted this audit on July 8, 2020 — management decision was due January 8, 2021.

2019-007
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2019-007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CDBG ? Entitlement Grants Cluster; Community Development Block Grant-Entitlement CFDA Number: Program (CFDA No. 14.218); Compliance Requirement: Reporting ? Financial Administration (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding 2018-009. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records that present the financial position of the program and results of its operations. Criteria 24 CFR 570.507 Subpart J Reports (d) Other reports. Recipients may be required to submit such other reports and information as HUD determines are necessary to carry out its responsibilities under the Act or other applicable laws. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation We recommend that management should strengthen it?s procedures an action to reconcile in a timely manner the federal funds reports with the accounting records in order to procedure reliable financial data. Questioned Costs None

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Finding Reference 2019-007 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CDBG ? Entitlement Grants Cluster; Community Development Block Grant-Entitlement CFDA Number: Program (CFDA No. 14.218); Compliance Requirement: Reporting ? Financial Administration (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding 2018-009. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records that present the financial position of the program and results of its operations. Criteria 24 CFR 570.507 Subpart J Reports (d) Other reports. Recipients may be required to submit such other reports and information as HUD determines are necessary to carry out its responsibilities under the Act or other applicable laws. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation We recommend that management should strengthen it?s procedures an action to reconcile in a timely manner the federal funds reports with the accounting records in order to procedure reliable financial data. Questioned Costs None

Corrective Action Plan

The Program?s Management has an accounting program (Rock Solid System - SIMA), which contains adequate procedures for the timely conciliation of federal funds reporting with accounting records and to produce reliable financial data. Also, the acting Finance and Budget Director will discuss the recommendation included in this finding with the Program?s Management in order to ensure its complete implementation. A follow-up procedure will be established until the corrective action has been completed. Implementation Date: During the 2020-2021 fiscal year Responsible Persons: Mr. Jose Leon Gaud Finance and Budget Director Mr. Osvaldo Maldonado Fiscal Officer

Prior Finding References

2018-009

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2019-008
Reporting
MATERIAL WEAKNESSREPEAT

Finding Reference 2019-008 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Reporting ? Accounting Records (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2018-012 and 2017-007. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records for the Section 8 Housing Choice Vouchers to fairly present the financial position of the program and results of its operations. The financial information reported in Voucher Management System (VMS) is based on accounting information compiled from different sources and not from a complete set of accounting records. Criteria 24 CFR Subpart C, Part 85.20 (b) (2) states that the grantees and sub grantees must maintain records which adequately identify the source and application of funds, provided for financially-assisted activities. These records must contain information pertaining to grant or sub grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. 24 CFR Subpart D Section 982.158 (a), established that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms or record-keeping. The municipality must comply with the financial reporting requirements in 24 CFR part 5, subpart K. The financial management system of other grantees and sub-grantees must meet the following standards: ? Financial reporting: Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or sub-grant. ? Accounting records: Grantees and sub-grantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or sub-grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation Management should take necessary steps to establish and maintaining proper internal controls and periodic monitoring procedures to ensure the correct recognition of the Program?s financial and budgetary transactions in a complete set of accounting records, using the double-entry system. The Program must give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports to ascertain that: (1) the accounting system complies with state and federal laws, (2) all the transactions related to assets, liabilities, revenues and expenditures is recorded and reconciled in a timely manner. Questioned Costs None

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Finding Reference 2019-008 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Reporting ? Accounting Records (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2018-012 and 2017-007. Statement of Condition During our audit, we noted that the Program did not maintain an adequate set of accounting records for the Section 8 Housing Choice Vouchers to fairly present the financial position of the program and results of its operations. The financial information reported in Voucher Management System (VMS) is based on accounting information compiled from different sources and not from a complete set of accounting records. Criteria 24 CFR Subpart C, Part 85.20 (b) (2) states that the grantees and sub grantees must maintain records which adequately identify the source and application of funds, provided for financially-assisted activities. These records must contain information pertaining to grant or sub grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. 24 CFR Subpart D Section 982.158 (a), established that the PHA must maintain complete and accurate accounts and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms or record-keeping. The municipality must comply with the financial reporting requirements in 24 CFR part 5, subpart K. The financial management system of other grantees and sub-grantees must meet the following standards: ? Financial reporting: Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or sub-grant. ? Accounting records: Grantees and sub-grantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or sub-grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. Cause of Condition Adequate internal controls and proper monitoring procedures do not exist to ensure the maintenance of a complete set of accounting records as required by the Program?s regulations and grant agreement. Also, the accounting personnel does not possess the adequate training to ensure a proper recognition of the Program?s financial transactions. Effect of Condition The Program?s accounting system did not provide updated and complete financial information that present the financial position and the result of operations and the change in fund balances. Such information is necessary to take management decisions. In addition, the Program's reports related to federal funding may be misleading for internal management decision making and for the reliability of external financial reporting. Recommendation Management should take necessary steps to establish and maintaining proper internal controls and periodic monitoring procedures to ensure the correct recognition of the Program?s financial and budgetary transactions in a complete set of accounting records, using the double-entry system. The Program must give financial training to the personnel in charge of the accounting record-keeping and preparation of the financial reports to ascertain that: (1) the accounting system complies with state and federal laws, (2) all the transactions related to assets, liabilities, revenues and expenditures is recorded and reconciled in a timely manner. Questioned Costs None

Corrective Action Plan

The Program?s Management has an accounting program (Rock Solid System - SIMA), which contains adequate procedures for the timely conciliation of federal funds reporting with accounting records and to produce reliable financial data. Also, the acting Finance and Budget Director will discuss the recommendation included in this finding with the Program?s Management in order to ensure its complete implementation. A follow-up procedure will be established until the corrective action has been completed. Implementation Date: During the 2020-2021 fiscal year Responsible Persons: Mr. Jose Leon Gaud Finance and Budget Director Mr. Osvaldo Maldonado Fiscal Officer

Prior Finding References

2018-012

About Reporting →
2019-009
Reporting
MATERIAL WEAKNESS

Finding Reference 2019-009 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition We performed a Reporting Test and did not find evidence that GAAP-based unaudited financial data was submitted electronically to HUD for the fiscal year 2018-2019. Criteria OMB No. 2535-0107, 24 CFR Section 5.801, requires PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD trough the Real Estate Assessment Center (REAC). The FASS-PH system is one of HUD?s main monitoring and oversight systems for the HCVP. Cause of Condition The Municipality did not maintain evidence of the Real Estate Assessment Center (REAC) audited information submission for the fiscal year 2018-2019. Effect of Condition The PHA did not comply with the OMB No. 2535-0107, 24 CFR Section 5.801. Recommendation We recommend to the Municipality?s management to instruct the program accountant to submit timely GAAP-based unaudited and audited financial information electronically to HUD. Questioned Costs None

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Finding Reference 2019-009 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Section 8 Housing Choice Vouchers (CFDA No. 14.871) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition We performed a Reporting Test and did not find evidence that GAAP-based unaudited financial data was submitted electronically to HUD for the fiscal year 2018-2019. Criteria OMB No. 2535-0107, 24 CFR Section 5.801, requires PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD trough the Real Estate Assessment Center (REAC). The FASS-PH system is one of HUD?s main monitoring and oversight systems for the HCVP. Cause of Condition The Municipality did not maintain evidence of the Real Estate Assessment Center (REAC) audited information submission for the fiscal year 2018-2019. Effect of Condition The PHA did not comply with the OMB No. 2535-0107, 24 CFR Section 5.801. Recommendation We recommend to the Municipality?s management to instruct the program accountant to submit timely GAAP-based unaudited and audited financial information electronically to HUD. Questioned Costs None

Corrective Action Plan

We will improve our internal controls procedures related to record keeping and year adjustments in order to ensure compliance with the August 31 federal requirement. Implementation Date: During the 2020-2021 fiscal year Responsible Persons: Mrs. Ana Rita Hernandez Section 8 Accountant

About Reporting →
2019-010
Reporting
MATERIAL WEAKNESS

Finding Reference 2019-010 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation (CFDA No. 14.856) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition We performed a Reporting Test and did not find evidence that GAAP-based unaudited financial data was submitted electronically to HUD for the fiscal year 2018-2019. Criteria OMB No. 2535-0107, 24 CFR Section 5.801, requires PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD trough the Real Estate Assessment Center (REAC). The FASS-PH system is one of HUD?s main monitoring and oversight systems for the HCVP. Cause of Condition The Municipality did not maintain evidence of the Real Estate Assessment Center (REAC) audited information submission for the fiscal year 2018-2019. Effect of Condition The PHA did not comply with the OMB No. 2535-0107, 24 CFR Section 5.801. Recommendation We recommend to the Municipality?s management to instruct the program accountant to submit timely GAAP-based unaudited and audited financial information electronically to HUD. Questioned Costs None

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Full finding narrative

Finding Reference 2019-010 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title and CFDA Number: Lower Income Housing Assistance Program ? Section 8 Moderate Rehabilitation (CFDA No. 14.856) Compliance Requirement: Reporting ? Financial Reporting (L) (MW) Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) Statement of Condition We performed a Reporting Test and did not find evidence that GAAP-based unaudited financial data was submitted electronically to HUD for the fiscal year 2018-2019. Criteria OMB No. 2535-0107, 24 CFR Section 5.801, requires PHAs to submit timely GAAP-based unaudited and audited financial information electronically to HUD trough the Real Estate Assessment Center (REAC). The FASS-PH system is one of HUD?s main monitoring and oversight systems for the HCVP. Cause of Condition The Municipality did not maintain evidence of the Real Estate Assessment Center (REAC) audited information submission for the fiscal year 2018-2019. Effect of Condition The PHA did not comply with the OMB No. 2535-0107, 24 CFR Section 5.801. Recommendation We recommend to the Municipality?s management to instruct the program accountant to submit timely GAAP-based unaudited and audited financial information electronically to HUD. Questioned Costs None

Corrective Action Plan

We will improve our internal controls procedures related to record keeping and year adjustments in order to ensure compliance with the August 31 federal requirement. Implementation Date: During the 2020-2021 fiscal year Responsible Persons: Mrs. Ana Rita Hernandez Section 8 Accountant

About Reporting →
2019-011
Reporting
MATERIAL WEAKNESS

Finding Reference 2019-011 Federal Agency: U.S. Department of Health and Human Services Federal Program Title and CFDA Number: Head Start Program (CFDA No. 93.600) Compliance Requirement: Reporting ? Financial Administration Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2018-013 and 2016-009. Statement of Condition The financial information reported in the financial reporting is based on accounting information compiled from different sources and not from a complete set of accounting records, resulting in errors in the amounts reported in the Federal Financial Report (Standard Form 425) submitted during program year. As an alternate procedure, we compared the amounts reported as federal expenditures in the monthly Financial Reports and the amounts detailed in the supporting accounting documentation used for the preparation of these reports and there were significant differences between the amounts reported and the ones detailed in such documentation. Criteria The OMB Common Rules, Subpart C, Section .20 (b) (1), states that the grantee must maintain internal control procedures that permits proper tracing of funds to the accounting records. Also, it requires accurate, current and complete disclosure of financial results. Cause of Condition Adequate internal controls do not exist to ensure the correctness of the quarterly reports submitted to the federal agency. Also, proper monitoring procedures do not exist for the information reported in the Federal Financial Report (SF-425). Effect of Condition The Program is not in compliance with the Common Rules, Subpart C, Section .20 (b) (1). Recommendation We recommend the Program establishes monitoring procedures to ensure the accuracy and completeness of accounting records and correct preparation and submission of the monthly financial reports. Questioned Costs None

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Full finding narrative

Finding Reference 2019-011 Federal Agency: U.S. Department of Health and Human Services Federal Program Title and CFDA Number: Head Start Program (CFDA No. 93.600) Compliance Requirement: Reporting ? Financial Administration Type of finding: Material Weakness in Internal Control (MW), Instance of Noncompliance (NC) This finding is similar to prior-year finding(s) 2018-013 and 2016-009. Statement of Condition The financial information reported in the financial reporting is based on accounting information compiled from different sources and not from a complete set of accounting records, resulting in errors in the amounts reported in the Federal Financial Report (Standard Form 425) submitted during program year. As an alternate procedure, we compared the amounts reported as federal expenditures in the monthly Financial Reports and the amounts detailed in the supporting accounting documentation used for the preparation of these reports and there were significant differences between the amounts reported and the ones detailed in such documentation. Criteria The OMB Common Rules, Subpart C, Section .20 (b) (1), states that the grantee must maintain internal control procedures that permits proper tracing of funds to the accounting records. Also, it requires accurate, current and complete disclosure of financial results. Cause of Condition Adequate internal controls do not exist to ensure the correctness of the quarterly reports submitted to the federal agency. Also, proper monitoring procedures do not exist for the information reported in the Federal Financial Report (SF-425). Effect of Condition The Program is not in compliance with the Common Rules, Subpart C, Section .20 (b) (1). Recommendation We recommend the Program establishes monitoring procedures to ensure the accuracy and completeness of accounting records and correct preparation and submission of the monthly financial reports. Questioned Costs None

Corrective Action Plan

The acting Finance and Budget Director will discuss the recommendation included in this finding with the Program?s Management in order to ensure the complete implementation. A follow-up procedure will be established until the corrective action has been completed. Implementation Date: During the 2020-2021 fiscal year Responsible Persons: Mr. Javier Negron Olivieri Head Start Program Director Mr. Amarelys Berrios Head Start Fiscal Officer

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FY 2018-06-30

FAC accepted this audit on June 27, 2019 — management decision was due December 27, 2019.

2018-008
Cash Management

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-009
Reporting
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-010
Cash Management

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-011
Eligibility
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-012
Reporting
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-007

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2018-013
Reporting
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-009

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FY 2017-06-30

FAC accepted this audit on June 28, 2018 — management decision was due December 28, 2018.

2017-006
Special Tests & Provisions

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-007
Reporting
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-008
Reporting
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-009

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FY 2016-06-30

FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.

2016-007
Cash Management
REPEAT

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2015-007

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2016-008
Equipment & Real Property

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-009
Reporting
REPEAT

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2015-009

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Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.

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