THE HOUSING AUTHORITY OF LAFOURCHE PARISH

Finding 2024-002 – Non-compliance with Internal Procurement Policy (Other Matter) Capital Fund Program – Assistance Listing No. 14.872; Grant Period - Fiscal Year-Ended September 30, 2024 Repeat Finding – Fiscal Year 2023 Audit Finding #2023-002 Criteria Public Housing Authorities (PHA’s) should procure federally-funded contracts in accordance with a formal, documented internal Procurement Policy based on federal procurement guidelines, including HUD Handbook 7460.8, Rev. 2, Procurement Handbook for Public Housing Agencies. PHA’s are prohibited from awarding contracts to contractors who have been suspended or debarred from performing contracts funded with federal subsidies. Additionally, the Authority’s Procurement Policy dictates full compliance with the Handbook. PHA’s are permitted to comply with the applicable regulations by A) searching the Excluded Parties List System (EPLS) for the prospective contractor, or B) attaining a certified statement from the contractor in which the contractor certifies against suspension or debarment. Condition and Perspective Three Capital Fund Program funded contract awards were sampled. Two applicable contracts awarded in the amounts of $35,841 and $51,264, did not contain the contractors’ certifications against suspension and debarment or evidence that the EPLS was searched for the contractors. Questioned Costs – None Cause Lack of knowledge of federal procurement requirements among applicable personnel administering contract awards. Effect Non-compliance with the Authority’s Procurement Policy and federal regulations. Recommendation We recommend that the Authority attain certification against suspension and debarment or search the EPLS for prospective contractors prior to awarding contracts. Management’s Response The Authority will attain certification against suspension and debarment or search the EPLS for prospective contractors prior to awarding contracts. The Authority’s Executive Director, Erial Branch, has assumed the responsibility of executing this corrective action as of April 30, 2025.

Non-compliance with Internal Procurement Policy Capital Fund Program – Assistance Listing No. 14.872; Grant Period - Fiscal Year-Ended September 30, 2024 Corrective Action The Authority will attain certification against suspension and debarment or search the EPLS for prospective contractors prior to awarding contracts. The Authority’s Executive Director, Erial Branch, has assumed the responsibility of executing this corrective action as of April 30, 2025.

2023-002

Finding 2024-003 – Non-compliance with the Davis-Bacon Act (Other Matter) Capital Fund Program – Assistance Listing No. 14.872; Grant Period - Fiscal Year-Ended September 30, 2024 Repeat Finding – Fiscal Year 2023 Audit Finding #2023-003 Criteria The Davis-Bacon Act applies to contractors and subcontractors performing on federally funded or assisted contracts in excess of $2,000 for the construction, alteration, or repair (including painting and decorating) of public buildings or public works. Title 29 of the Code of Federal Regulations, Subtitle A, Part 5, Subpart A describes the Davis-Bacon Act and includes a requirement that applicable agencies shall include in their contracts a provision that the contractor or subcontractor comply with those requirements of the Department of Labor regulations (the Davis-Bacon Act). 29 CFR, Subtitle A, Part 5, Subpart A 5.5-A.3 Payrolls and Basic Records includes a requirement for the contractor or subcontractor to submit to the non-federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition and Perspective During audit fieldwork, auditors sampled two applicable contactor files for compliance with the Davis Bacon Act. The Authority was unable to provide certified payrolls for both of the contractors which were required to submit certified payrolls for each week work was performed. A total of $122,341 was expended under the contracts during the fiscal year. Additionally, the Prevailing Wage Rate Clause was not included in one of the applicable contracts. Questioned Costs - None Cause Lack of knowledge of the Davis-Bacon Act requirements among applicable personnel administering contract award and contract oversight. Effect Non-compliance with the Davis-Bacon Act. Recommendation We recommend that the Authority attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. Management’s Response The Authority will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. The Authority’s Executive Director, Erial Branch, has assumed the responsibility of executing this corrective action as of April 30, 2025.

Non-compliance with the Davis-Bacon Act Capital Fund Program – Assistance Listing No. 14.872; Grant Period - Fiscal Year-Ended September 30, 2024 Corrective Action The Authority will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. The Authority’s Executive Director, Erial Branch, has assumed the responsibility of executing this corrective action as of April 30, 2025.

2023-003

Non-compliance with the Davis-Bacon Act (Material Weakness, Material Non-Compliance) Capital Fund Program – Assistance Listing No. 14.872; Grant Period - Fiscal Year-Ended September 30, 2023 Criteria The Davis-Bacon Act applies to contractors and subcontractors performing on federally funded or assisted contracts in excess of $2,000 for the construction, alteration, or repair (including painting and decorating) of public buildings or public works. Title 29 of the Code of Federal Regulations, Subtitle A, Part 5, Subpart A describes the Davis-Bacon Act and includes a requirement that applicable agencies shall include in their contracts a provision that the contractor or subcontractor comply with those requirements of the Department of Labor regulations (the Davis-Bacon Act). 29 CFR, Subtitle A, Part 5, Subpart A 5.5-A.3 Payrolls and Basic Records includes a requirement for the contractor or subcontractor to submit to the non-federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition and Perspective During audit fieldwork, auditors sampled two contactor files for compliance with the Davis Bacon Act. The Authority was unable to provide certified payrolls for one of the two contractors which were required to submit certified payrolls for each week work was performed. $481,610 was expended under the contract during the fiscal year. Additionally, the Prevailing Wage Rate Clause was not included in the applicable contract. Questioned Costs - None Cause Lack of knowledge of the Davis-Bacon Act requirements among applicable personnel administering contract award and contract oversight. Effect Non-compliance with the Davis-Bacon Act. Recommendation We recommend that the Authority attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. Management’s Response The Authority will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. The Authority’s Executive Director, Erial Branch, has assumed the responsibility of executing this corrective action as of August 1, 2024.

The Authority will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. The Authority’s Executive Director, Erial Branch, has assumed the responsibility of executing this corrective action as of August 1, 2024.

Tenant File Documentation Maintenance (Significant Deficiency, Noncompliance) Public Housing Program – Assistance Listing No. 14.850a; Grant period – Fiscal Year Ended September 30, 2023 Criteria The Public Housing Occupancy Guidebook and other HUD PIH Notices and Handbooks provide requirements and guidance for which the Public Housing Program is to be administered and operated under with respect to tenant eligibility and reexaminations. Condition and Perspective During audit fieldwork, forty Public Housing Program tenant files were requested for review for compliance with Program eligibility and reexamination requirements. The following omissions were noted from the review: 1) Three files were missing at least one birth certificate or valid identification 2) Two files were missing a third-party verification of income Cause Failure to execute controls over tenant file documentation requirements. Effect Non-compliance with tenant file documentation requirements. Questioned Costs – None noted Recommendation We recommend that the Authority implement and execute strengthened controls over tenant file documentation maintenance processes and procedures. Management’s Response The Authority will implement and execute strengthened controls over tenant file documentation maintenance processes and procedures. Erial Branch, Executive Director, has assumed the responsibility of executing strengthened controls over tenant file documentation maintenance as of September 1, 2024.

The Authority will implement and execute strengthened controls over tenant file documentation maintenance processes and procedures. Erial Branch, Executive Director, has assumed the responsibility of executing strengthened controls over tenant file documentation maintenance as of September 1, 2024.

2002-002

Noncompliance With Waiting List and Move-in Policies and Procedures (Other Matter) Section 8 Housing Choice Voucher Program – Assistance Listing No. 14.871; Grant period – Fiscal Year Ended September 30, 2023 Criteria The Authority’s Section 8 Housing Choice Voucher Program participant admittance policies and procedures dictate selection of potential program participants from its waiting list. Condition and Perspective Three participants were issued vouchers without being selected from the waiting list. The waiting list was bypassed for these participants. There were no preferences or other reasons for bypassing the waiting list. Applicable fiscal year 2023 housing assistance payments expenditures totaled $28,135. Fiscal year 2024 housing assistance payments expenditures total $20,239 through the date of this Report. Cause Lack of sufficient monitoring over program admittance procedures. Effect Noncompliance with waiting list and move-in policies and procedures. Questioned Costs – Applicable fiscal year 2023 housing assistance payments expenditures totaled $28,135. Fiscal year 2024 housing assistance payments expenditures total $20,239 through the date of this Report. Recommendation We recommend that the Authority implement and execute increased monitoring and approval procedures over the program admittance process. Management’s Response The Authority will implement and execute increased monitoring and approval procedures over the program admittance process. Erial Branch, Executive Director, has assumed the responsibility of implementing and executing increased monitoring and approval procedures over the program admittance process, and anticipates the strengthened controls to be in place by August 1, 2024.

The Authority will implement and execute increased monitoring and approval procedures over the program admittance process. Erial Branch, Executive Director, has assumed the responsibility of implementing and executing increased monitoring and approval procedures over the program admittance process, and anticipates the strengthened controls to be in place by August 1, 2024.

Finding 2022-002 ? Tenant File Documentation Maintenance (Material Weakness, Noncompliance) Public Housing Program ? CFDA No. 14.850a; Grant period ? fiscal year ended September 30, 2022 Criteria The Public Housing Occupancy Guidebook and other HUD PIH Notices and Handbooks provide requirements and guidance for which the Public Housing Program is to be administered and operated under with respect to tenant eligibility and reexaminations. Condition and Perspective During audit fieldwork, forty Public Housing Program tenant files were requested for review for compliance with Program eligibility and reexamination requirements. The following omissions were noted from the review: 1) Five files were missing Lead-Based Paint Disclosure Forms 2) Five files were missing Community Service Requirements Forms 3) One file was missing a signed HUD 9886 Authorization for Release of Information Form 4) One file was missing a third-party verification of income Cause Failure to execute controls over tenant file documentation requirements. Effect Non-compliance with tenant file documentation requirements. Questioned Costs ? None noted Recommendation We recommend that the Authority implement and execute strengthened controls over tenant file documentation maintenance processes and procedures. Reply The Authority will implement and execute strengthened controls over tenant file documentation maintenance processes and procedures. Erial Branch, Executive Director, has assumed the responsibility of executing strengthened controls over tenant file documentation maintenance as of April 30, 2023.

Finding 2022-002 ? Tenant File Documentation Maintenance Corrective Action The Authority will implement and execute strengthened controls over tenant file documentation maintenance processes and procedures. Erial Branch, Executive Director, has assumed the responsibility of executing strengthened controls over tenant file documentation maintenance as of April 30, 2023.