Blackfeet Housing

2021-1 Condition: Deficiencies Noted in Maintenance of Resident Files Deficiencies noted in the review of the forty (40) Public Rental resident files: 18 of 40 Rental files selected lacked a timely Annual Recertification 18 of 40 Rental files selected lacked 3rd party Income/Rent Calculation 18 of 40 Rental files selected lacked accurate Family Data 18 of 40 Rental files selected lacked Waiting List Support for Move-In Deficiencies noted in the review of the twenty-five (25) Mutual Help resident files: 25 of 25 files selected lacked an update for the file FY 2021 During the review of Mutual Help outstanding balances it was noted that due to an oversight error the balances for all accounts were written off. CFDA Number: 14.867 Questioned Costs: None Cause: The Authority?s deficiency in its resident files stems from some lack of controls concerning HUD requirements and procedures. Effect: The Authority has not been in complete compliance with the above HUD and policy requirements. Criteria: 24 CFR requirements for Indian Housing eligibility. Recommendation: In general, we continue to recommend a review of the recertification process to determine areas of weakness. We also recommend more standardization in file organization of information. Views of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the condition.

2021-3 Condition: Small Purchases Procurement During the review of five (5) contracts selected for audit, the following conditions were noted: 5 of 5 files lacked documentation of preliminary cost analysis for scope of work to be performed. 5 of 5 files lacked documentation of suspension and debarment check for each contractor 5 of 5 files lacked documentation of lowest responsible bidder being selected as required by policy 5 of 5 files lacked documentation of bid advertisement 2 of 5 files had change orders outside the scope of the original contact 5 of 5 Materials Contracts were not procured in compliance with policy CFDA Number: 14.867, 14.862 Questioned Costs: Undetermined Cause: The Authority's deficiency in procurement and contracts stems from a lack of certain controls concerning HUD requirements and procedures. Effect: The Authority has not been in complete compliance with the above HUD requirements. Criteria: HUD Regulation regarding 24 CFR 85.36 Recommendation: We recommend that all contracts have the same level of documentation of procurement for small purchases contracts and that the Authority add additional support for contracts where only one bid for services was available. Views of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the condition.

2021-4 Condition: Deficiencies Noted in Our Examination of Emergency Rental Assistance (ERA) Files Out of 15 ERA Files the following deficiencies were noted: 5 ERA Files lacked sufficient support for the amount of rental assistance paid to the participant. Additionally, the Authority could not provide a listing of participants served by the program including the essential items tracked by the ERA guidance. CFDA Number: 21.023 Questioned Costs: None Cause: The Authority did not have adequate internal controls (monitoring) to determine that they were not in compliance with regulations or their own policies. Effect: The Authority has not been in complete compliance with the Department of Treasury and HUD guidance. Criteria: The Authority is required by regulation and their own administrative policies to perform certain procedures to ensure that the program is administered in accordance with HUD regulations. Recommendation: We recommend that the Authority review policies and procedures to be in complete compliance with all Department of Treasury and HUD regulations. Views of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the condition.

2021-6 Condition: Deficiencies in the Substantiation of the Recorded Inventory Balance at December 31, 2021 During the review of the year-end inventory report, we noted that when we made actual test counts during our audit fieldwork, most of the line items recorded on the final inventory sheets reflected material differences from the perpetual inventory system. The overall cost amounts appeared to be material when we perform test counts and average price cost comparisons. To support agreement with the perpetual system, the Authority did but did not correct the differences between the perpetual inventory system, the general ledger books on December 31, 2021 and actual physical inventories on hand. We observed that physical controls and security at the inventory locations do not appear to be adequately staffed and secure. CFDA Number: 14.867 Questioned Costs: None Cause: The Authority's deficiency in the safeguard to Equipment, Materials, and Supplies stems from lack of compliance HUD requirements and Loss of key personnel with knowledge of the HUD submission requirements. Effect: The Authority?s controls and security at its inventory locations do not appear to be completely adequate and secure. . Criteria: HUD Regulation regarding procurement in 24 CFR 85.32d paragraphs 1-5 Management Requirements. Recommendation: We recommend that steps are taken to review the overall inventory for obsolescence, sale or donate unusable items. We also continue to recommend the Authority seek more separation by location its inventory purchased for Tax Credit properties and new developments. This process will enhance better internal controls over materials and supplies. Views of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the condition.

2020-1 Condition: Deficiencies Noted in Maintenance of Resident Files During the review of the sixty (60) resident files selected for audit from all Housing programs (Rental, Mutual Help, Voucher and VASH), the following deficiencies were noted: 2 of 4 Mutual Help files selected lacked Annual Recertification 8 of 10 Conveyance Eligible New Mutual Help Files were not updated by Blackfeet Housing staff in FY 2020 to ensure a timely conveyance of these homes to the participant 6 Rental files selected lacked a timely Annual Recertification 2 Rental files selected lacked an Annual Inspection 5 Rental files selected lacked accurate Rent Calculation 5 Rental files selected lacked 3rd Party Income 3 Rental file selected lacked accurate Family Data 3 Rental file selected lacked Waiting List Support for Move-In 1 Rental Files selected lacked signed release of information form CFDA Number: 14.867 Questioned Costs: None Cause: The Authority?s deficiency in its resident files stems from some lack of controls concerning HUD requirements and procedures. Effect: The Authority has not been in complete compliance with the above HUD and policy requirements. Criteria: 24 CFR requirements for Indian Housing eligibility. Recommendation: In general, we continue to recommend a review of the recertification process to determine areas of weakness. We also recommend more standardization in file organization of information. Views of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the condition.

2020-2 Condition: Deficiencies in the Substantiation of the Recorded Inventory Balance at December 31, 2020 During the review of the year-end inventory report, we noted that when we made actual test counts during our audit fieldwork, most of the line items recorded on the final inventory sheets reflected material differences from the perpetual inventory system. The overall cost amounts appeared to be material when we perform test counts and average price cost comparisons. To support agreement with the perpetual system, the Authority did not make regular quarterly test counts from January 2020 until December 2020 to correct the differences between the perpetual inventory system, the general ledger books at December 31, 2020, and actual physical inventories on hand. We observed that physical controls and security at the inventory locations do not appear to be adequately staffed and secure. CFDA Number: 14.867, 14.862 Questioned Costs: None Cause: The Authority's deficiency in the safeguard of Equipment, Materials, and Supplies stems from lack of compliance HUD requirements and Loss of key personnel with knowledge of the HUD submission requirements Effect: The Authority's controls and security at its inventory locations do not appear to be completely adequate and secure. Criteria: HUD Regulation regarding procurement in 24 CFR 85.32d paragraphs 1-5 Management Requirements Recommendation: We recommend that steps are taken to review the overall inventory for obsolescence, sale or donate unusable items. We also continue to recommend the Authority seek more separation by location its inventory purchased for Tax Credit properties and new developments. This process will enhance better internal controls over materials and supplies. Views of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the condition.

2020-3 Condition: Small Purchases Procurement During the review of five (5) contracts selected for audit, the following conditions were noted: 5 of 5 files lacked documentation of preliminary cost analysis for scope of work to be performed. 5 of 5 files lacked documentation of suspension and debarment check for each contractor 5 of 5 files lacked documentation of lowest responsible bidder being selected as required by policy 5 of 5 files lacked documentation of bid advertisement 2 of 5 files had change orders outside the scope of the original contact CFDA Number: 14.867, 14.862 Questioned Costs: Undetermined Cause: The Authority's deficiency in procurement and contracts stems from a lack of certain controls concerning HUD requirements and procedures. Effect: The Authority has not been in complete compliance with the above HUD requirements. Criteria: HUD Regulation regarding 24 CFR 85.36 Recommendation: We recommend that all contracts have the same level of documentation of procurement for small purchases contracts and that the Authority add additional support for contracts where only one bid for services was available. Views of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the condition.

2020-4 Condition: Deficiency noted in proper collateralization of the IHA cash equivalents and investments in Fiscal year 2020, and as of the end of audit field work on August 20, 2021 During our audit, we noted that although the Authority has executed HUD form 52736 (General Depository Agreement) with certain of its financial institutions, the Authority did not have evidence of collateralization from all of these institutions as required in HUD Form 52736, paragraph 2, for certain funds on account with financial institutions. CFDA Number: 14.867, 14.862 Questioned Costs: None Cause: The Authority's deficiency stems from a lack of controls concerning HUD requirements and procedures. Effect: The Authority has not been in complete compliance with HUD Requirements. Criteria: HUD Form 52736 (General Depository Agreement), paragraph 2 states "any portion of the Authority funds not insured by a Federal insurance organization shall be fully (100%) and continuously collateralized with specific and identifiable U.S. Government of Agency securities prescribed by HUD and held by a third party independent of the investment institution." Recommendation: We recommend that the Authority monitor collateral for adequate coverage. If the Bank refuses to support collateralization as required by HUD, we also recommend that the Authority consider securing other banking arrangements. Views of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the condition.

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