SANTO DOMINGO TRIBAL HOUSING AUTHORITY

EIN: 850443030

UEI: EK1CP9HD98M5

5
Audit Years
22
Total Findings
12
Repeat Findings

FY 2023-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 21, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 21, 2027 (155 days from today).

What is a management decision? →
2023-003
Reporting
REPEAT
Condition

Condition: The audit report and data collection form for the year ended December 31, 2023 was not submitted to the Federal Audit Clearinghouse by the required due date. Criteria: In accordance with Uniform Guidance, the Data Collection Form and reporting package must be submitted to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the fiscal year-end. Questioned Cost: None. Cause: Due to changes in management during the year, the Authority experienced delays in completing the audit, which resulted in the reporting package not being finalized in time for submission. Effect: Failure to submit the reporting package by the required deadline results in noncompliance with Uniform Guidance reporting requirements and may subject the Authority to increased oversight or potential funding risks.

Corrective Action Plan

Management’s Response: SDTHA’s management concurs that a problem exists with financial reporting for the IHBG award. During the HUD monitoring for 2019 and the subsequent audits, issueswere noted with expenditures. These issues were brought up to management in 2020, which resulted in having to complete the 2018 audit. The audit reports are cumulative, ending balances from the prior year are carried over to the beginning of the next year, so this has slowed down the completion of timely filing. SDTHA developed a plan to have 2023 completed by quarter two of 2026, 2024 and 2025 audits to be completed before the end of 2026 Timeline and Estimated Completion Date: December 31, 2026 Responsible Official: Lorrie Chavez, Executive Director and Jonah Garcia, Finance Officer

Prior Finding References

2022-002

About Reporting →
2023-004
Reporting
REPEAT
Condition

Condition: During our compliance testwork over major federal awards, we noted the Authority did not submit one of three annual Federal Financial Report (“SF-425”) required for 2023. Criteria: Under the Indian Housing Block Grant – NAHASDA program, recipients are required to prepare and submit financial reports within 90 days after the fiscal year-end. Questioned Cost: None. Cause: The Authority did not have adequate procedures in place to track reporting requirements and ensure timely preparation and submission of SF-425. Effect: Failure to submit required reports in a timely manner may result in noncompliance with federal reporting requirements and could impact funding or oversight by the grantor agency.

Corrective Action Plan

Management’s Response: The SDTHA management concurs that a problem exists with the financial reporting for the IHBG award. During the 2019 HUD monitoring, it was noted that there were issues with expenditures and what was allowable expenses. SDTHA management has been working diligently to correct and ensure all expenditures are all allowable. SDTHA management will complete all 425’s once the audits have been completed. Timeline and Estimated Completion Date: December 31, 2026 Responsible Official: Jonah Garcia, Finance Officer

Prior Finding References

2022-005

About Reporting →

FY 2022-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on October 31, 2025. 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 May 1, 2026, which was (110 days ago).

What is a management decision? →
2022-002
Other
REPEAT
Prior Finding References

2021-001

About Other →
2022-003
Cost Allowability
REPEAT
Prior Finding References

2021-003

About Allowable Costs / Cost Principles →
2022-004
Eligibility
REPEAT
Prior Finding References

2021-004

About Eligibility →
2022-005
Reporting
REPEAT
Prior Finding References

2021-005

About Reporting →

FY 2021-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on April 3, 2025. 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 October 3, 2025, which was (320 days ago).

What is a management decision? →
2021-001
Reporting
REPEAT
Prior Finding References

2019-002

About Reporting →
2021-002
Activities Allowed or Unallowed / Cost Allowability
REPEAT
Prior Finding References

2019-003

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-003
Cost Allowability
REPEAT
Prior Finding References

2019-004

About Allowable Costs / Cost Principles →
2021-004
Eligibility
REPEAT
Prior Finding References

2019-005

About Eligibility →
2021-005
Reporting
REPEAT
Prior Finding References

2019-007

About Reporting →
2021-006
Equipment & Real Property
REPEAT
Prior Finding References

2019-010

About Equipment and Real Property Management →

FY 2019-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on May 16, 2022. 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 November 16, 2022, which was (1372 days ago).

What is a management decision? →
2019-002
Special Tests & Provisions
Condition

2019-002 ? Late Filing of the Federal Clearing House Report (Significant deficiency) Federal program information: Funding agency: U.S. Department of the Housing and Urban Development (HUD) Title: Indian Housing Block Grants CFDA number: 14.867 Grant/contract number 55IH3505460 Award period: January 1, 2019 ? December 31, 2019 Criteria: The Uniform Guidance requires the Federal Clearing House Data Collection Form and the audit report to be filed ether 30 days after the date of the audit report release or nine months after year end. Condition: The December 31, 2019 audit report and data collection form was not sent to the Federal Clearing House before the due date. Context: None. Questioned Cost: None. Cause and Effect: Due to the change in management, the Authority was not able to complete the audit timely to complete the Data Collection Form. As a result, the report was not available for filing to the Federal Audit Clearing House. Auditors? Recommendations: Management should monitor the Federal Clearing House deadlines and make sure all future audits are completed timely. Management?s Response: The required corrections to the December 31, 2018 financial statements and final completion of the 2018 audit field work was completed after the required deadline for filing with the federal clearinghouse for the 2018 audit. The reasons for the problem with timeliness of reporting included: 1. The numerous corrections and operational improvements that had to be reviewed and implemented in order to improve the operations and reporting of the Authority, 2. The significant amount of time that was spent by the Authority to unsuccessfully find supporting documentation and files necessary for the audit (many items had to be recreated) and 3. The challenges presented by COVID-19 to work with tenants and outside entities to complete the work needed for the audit. Many of these issues that were resolved for the December 31, 2018 audit should improve the reporting timelines for future audits.

Corrective Action Plan

2019-002 ? Late Filing of the Federal Clearing House Report Corrective action plan: We have completed the required internal processes to have financial statements ready for audit between 60 to 90 days prior to the filing date with the federal audit clearinghouse. Many of the requirements to meet this deadline have already been implemented as part of the December 31, 2018 audit. Personnel responsible for corrective action: The Authority?s management team is responsible for preparing the necessary financial and programmatic compliance records for audit. The Accountant and Finance Officer are responsible for final reconciliations and submission of information to the auditors for review. The Finance Officer works with the auditors to submit the reports to the federal audit clearinghouse after completion of the required audits. Estimated corrective action completion date: Audit field work for the December 31, 2020 financial statement audit is scheduled for early March 2022. Audit field work for the December 31, 2021 audit should be completed by April or May 2022. Both reports will be financial statement audits (regardless of the total federal expenditures) as part of the plan to improve financial reporting. By June 2022, all required financial statement audits for the Authority should be complete and submitted to the clearinghouse in a timely manner.

About Special Tests and Provisions →
2019-003
Activities Allowed or Unallowed
Condition

2019-003 ? Allowable Costs (Significant deficiency) Federal program information: Funding agency: U.S. Department of the Housing and Urban Development (HUD) Title: Indian Housing Block Grants CFDA number: 14.867 Grant/contract number 55IH3505460 Award period: January 1, 2019 ? December 31, 2019 Criteria: To be allowable under Federal Awards, costs must be necessary and reasonable for the performance and administration of the federal awards. Costs must meet the following criteria: 1) necessary and reasonable; 2) consistent with policies and procedures; 3) accorded consistent treatment; and 4) adequately documented. Condition: We noted the following transactions were the Authority charged the grant for activity that was for Domingo LLLP (a related party). Additionally, the supporting documentation for this transaction could not be located. Context: One of fifty-one transactions tested. Questioned Cost: None. Cause and Effect: The Authority charged the grant for unallowable costs to the grant. The Authority is not in compliance with program requirements regarding allowable costs. Auditors? Recommendations: Management should maintain all supporting documentation to document the activity charged to the grant and other activities of their employees. Management?s Response: As previously noted, the Finance Officer and Management of the Authority is different than the previous Management team. Much work has been done to ensure that the costs reported under the Authority?s federal awards meets the requirements of 2 CFR 200 as allowable costs. Many unallowable expenses were discovered, questioned and corrected. In addition, the accounting processes and procedures for many of the Authority?s activities have been improved since 2018 including review by management that costs are allowable, adequately documented and properly recorded. Although many of these changes have been implemented by 2021, documentation for the allowability of this one identified cost was unable to be supported in 2018. The prior management has coded it to the federal award and existing staff was unable to find the credit card supporting documentation. Accordingly, this charge with be adjusted in the subsequent years and properly charged to the correct fund.

Corrective Action Plan

2019-003 - Allowable Cost Corrective action plan: This cost shall be reduced in subsequent years from the IHBG grant and properly charged to the Tax Credit Project. Credit card statements are reviewed each month, supporting documentation is gathered and all costs are reviewed and posted to the proper fund as of 2021. With the implementation of the Purchasing system (Microix), all coding and purchases will be reviewed and approved with supporting documentation electronically filed for future support as of February 2022. Personnel responsible for corrective action: All procuring staff and management are responsible for obtaining support documentation and coding purchases to the proper account. The Supervisors, Executive Director and Finance staff also review the transactions before final payments are made. Estimated corrective action completion date: The December 31, 2020 and 2021 financial statement audits should show continue improvements in this area. Credit card supporting documentation has vast improved in 2020 and 2021. By February 2022, all supporting documentation and management/finance approvals will be documented through the Microix system.

About Activities Allowed or Unallowed →
2019-004
Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS
Condition

2019-004 ? Allocation of Payroll Costs (Material Weakness) Federal program information: Funding agency: U.S. Department of the Housing and Urban Development (HUD) Title: Indian Housing Block Grants CFDA number: 14.867 Grant/contract number 55IH3505460 Award period: January 1, 2019 ? December 31, 2019 Criteria: Per 2 CFR 200.306 and 2 CFR 200.405, a cost is allocable to a particular Federal or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Condition: The Authority uses a timesheet to document an employee?s time spent working on various projects. The amount charged by employee on the general ledger is not supported by a time sheet documenting the amount of actual time spend on the IHBG grant and other projects at the Authority. Additionally, the Authority had various timesheets being used and was not consistent with the use of a standard timesheet throughout the year. Context: Twenty-five of twenty-five payroll transactions tested. Questioned Cost: $38,838. Cause and Effect: The Authority does not have adequate policies and procedures in place for the allocation of salaries and benefits or cost sharing amounts for the programs they operate and manage. The Authority paid the employee benefits of staff of other programs with IHBG funds. The Authority lacked supporting documentation that the salary and benefits were paid for actual time spend working on the IHBG program during the year. The Authority is not in compliance with program requirements regarding the allocation of payroll costs. Auditors? Recommendations: Establish adequate internal controls to ensure payroll expenses and employee benefits are adequate and allowable and allocated to the appropriate funding sources. Management?s Response: Multiple payroll issues including allocation of payroll costs were identified by the Authority?s new management team in 2020. Although the MIP system has a payroll module that would allow proper allocation of payroll wages and benefits, this system was not being utilized. All payroll was being calculated on manual excel spreadsheets and entered into the MIP computerized system. Accordingly, errors were made due to the manual process. Much of the last half of 2020 and the first half of 2021 were spent on correcting these identified issues, verifying the accuracy of payroll reports and implementing the changes processes to properly report time.

Corrective Action Plan

2019-004 - Allocation of Payroll Costs Corrective action plan: The Authority worked diligently to improve the payroll process. The Authority?s staff were asked to keep records of the time that they spent on various projects and awards. This information was then recorded on their timesheets. Timeclocks for non-exempt staff were utilized. The MIP software and employee information was updated to properly utilize the MIP system to record and allocate payroll. The distribution codes that were previously set up to allocate all wages were replaced with entering of coding to match the time allocations on the timesheets. Corrective action plan ? continued: Employee leaves and benefits were also added to the system and are allocated according to the time worked each payperiod. This process was substantially complete by mid-2021. The Authority has been working with HUD, contract accountants and the auditors to come up with a methodology that will work to support time charges for 2018-2020 (prior to the proper allocation of time). Personnel responsible for corrective action: The Authority?s staff is responsible for preparing proper timesheets with hours coded to the projects that they worked on during the pay period. The Accountant enters the payroll data after verifying the hours and coding. The Finance Officer reviewed the time calculations for approval. These processes have been documented in writing as part of the Finance Office internal procedures. Estimated corrective action completion date: A final determination on payroll costs will need to be resolved with HUD for 2018-2020 (partial). FY 2021 will be the first full year of this allocation change.

About Allowable Costs / Cost Principles →
2019-005
Eligibility
Condition

2019-005 ? Eligibility (Significant Deficiency) Federal program information: Funding agency: U.S. Department of the Housing and Urban Development (HUD) Title: Indian Housing Block Grants CFDA number: 14.867 Grant/contract number 55IH3505460 Award period: January 1, 2019 ? December 31, 2019 Criteria: HUD regulations require that grantees verify that a family is income eligible based on anticipated annual income. The family is required to provide documentation to verify this determination. The recipient is required to maintain the documentation on which the determination of eligibility is based. Condition: The Authority was unable to provide the tenant income determination for eligibility for renters. Context: One of seven homebuyers files and five out of five tenant files reviewed for rental eligibility. Questioned Cost: None. Cause and Effect: Participant files lacked required tenant and homebuyer records to establish income eligibility, lease agreements, or lease purchase agreements, required maintenance and inspections and document compliance with other program requirements. the Authority is not in compliance with program requirements and unable to verify the status of their units. Auditors? Recommendations: the Authority should implement procedures to ensure that tenants are eligible based on annual income. Additionally, files should be standardized and maintained throughout the year. Management?s Response: As previously noted, the Authority?s new Tenant Services staff were brought in during 2020. At that time, complete file audits were conducted of all tenant files and numerous issues were noted. Since that time, rental files have been reconstructed so that all files have income and applications dating back to the time of move in. Homebuyer income eligibility and application records are in the process of being addressed now. During the timeframe noted, the Authority agrees that leases, annual recertifications and inspections were not completed in a timely manner. However, policy and procedures have been corrected and updated to address these items.

Corrective Action Plan

2019-005 - Eligibility Corrective action plan: The following procedures will address this finding: 1. Admissions and Occupancy policies as well as other Tenant Services policies have been reviewed and revised to address these concerns. 2. Annual recertifications will be conducted with an effective date of March 1st each year. (Currently, FY 2022 is in process). 3. HDS software has been installed to track tenant activities including applications, wait lists, move ins and outs, rents and payments, inspections, work orders, recertifications, and other tenant activity. I-pads have been purchased to take notes and pictures during inspections. This information will then be uploaded to HDS. 4. Due to COVID-19 protocols, only defined emergency maintenance is being completed on tenant units as well as some ?outdoor? improvements and maintenance. Inspections and required repairs will be completed once units are safe to enter. We are in the process of hiring additional maintenance staff for these planned corrections.Personnel responsible for corrective action: The Authority?s staff responsible for this corrective action plan will include: Tenant Services Manager and staff (income recertifications, updated leases, tenant file compliance and HDS documentations); Capital Improvement Manager and Maintenance Staff (Annual inspections and Identified repairs). Estimated corrective action completion date: The December 31, 2020 and 2021 audits should show continue improvements in this area. Currently, the annual certification is in process with an effective date of March 1, 2022. All leases and required documentation will be completed on rental units and then homeowner units to follow. We do not have a final date for the annual inspections but these will be scheduled once the COVID-19 restrictions are lifted. Repairs to units will be reviewed and prioritized. However, it may be a multi-year project to catch up on all required repair and maintenance needs due to limited staffing and potential funding.

About Eligibility →
2019-006
Procurement & Suspension/Debarment
Condition

2019-006 ? Procurement (Significant Deficiency) Federal program information: Funding agency: U.S. Department of the Housing and Urban Development (HUD) Title: Indian Housing Block Grants CFDA number: 14.867 Grant/contract number 55IH3505460 Award period: January 1, 2019 ? December 31, 2019 Criteria: Per 2 CFR 200.319, all procurement transactions be conducted in a manner providing full and open competition consistent with the standards set forth therein. In order to ensure objective contractor performance and eliminate unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work, or invitations for bids or request for proposals must be excluded from completing for such procurement. Condition: The Authority was unable to provide bid documentation for goods or services purchased valued more than $5,000. Context: Three of twenty-six purchases of goods and services did not have documentation of a formal bid process by the Authority. Questioned Cost: None. Cause and Effect: The Authority did not follow the procurement process requiring bids for goods and services. The Authority is not in compliance with program requirements regarding procurement. Auditors? Recommendations: The Authority should follow procurement procedures to ensure compliance with program requirements and federal regulations when procuring goods and services funded with IHBG funds. Management?s Response: Procurement documents were unable to be located in the instances noted above. It is unknown if the process was followed since the documentation was not located by new staff. Or if the required policy and procedures were not correctly followed. In any event, the procurement processes have been reviewed in detail by the current Authority staff and corrective actions have been taken.

Corrective Action Plan

2019-006 - Procurement Corrective action plan: The following activities are/were planned to address the procurement issues: 1. The current Authority?s staff have attended procurement training. 2. The procurement policy is in the process of being reviewed and updated. Step by step procedures are being drafted to provide future guidance for any new or existing employees. 3. A procurement software system (Microix) has been purchased and implemented. This system will require that all procurement activities be completed and entered into the system by the staff responsible for purchases (including any bidding or contracts for services). Support documentation will be scanned into the electronic files. The complete packet will then be reviewed and approved by the purchaser?s supervisor and the Executive Director before being sent to finance for processing. Proper coding, expenditure allowability, cost support and other required information will be obtained prior to any purchase being completed. Invoices received will be compared to the purchase information before payment is made. Personnel responsible for corrective action: All Authority staff with procurement responsibilities. Estimated corrective action completion date: The December 31, 2020 and 2021 audits should show continue improvements in this area. Training has already been completed and the use of Microix is scheduled to begin in February 2022. Procurement policy revisions will also be brought to the Board of Commissioners in 2022.

About Procurement and Suspension and Debarment →
2019-007
Reporting
Condition

2019-007 ? Reporting (Significant Deficiency) Federal program information: Funding agency: U.S. Department of the Housing and Urban Development (HUD) Title: Indian Housing Block Grants CFDA number: 14.867 Grant/contract number 55IH3505460 Award period: January 1, 2019 ? December 31, 2019 Criteria: The IHBG program is required to prepare and file financial and narrative reports by specific due dates. Condition: The Authority submitted the Federal Financial Report (Form 425) and Annual Performance Reports. However, the reports were not submitted by the specific due date. Context: (Form 425) Three of four Federal Financial Reports tested and one Annual Performance Report. Questioned Cost: None. Cause and Effect: Due to turnover in the finance department, the Authority was unable to prepare such reports timely. Auditors? Recommendations: The Authority should monitor due dates of the respective reports to make sure all applicable deadlines are met accordingly. Management?s Response: The current Authority management concurs that a problem exists with financial reporting for the IHBG grant. This report is cumulative (the ending balances from one year carry forward to the beginning balances of the next year). During the HUD monitoring review in 2018 and subsequent audits, issues were noted with expenditures. Once all the audits are complete and the review of expenditures by HUD to determine allowability, these reports can be caught up and properly filed. It should be noted that subsequent federal awards received for the IHBG Competitive Grant, CARES funding, Emergency Rental Assistance and Healthy Homes as well as other grant awards have all been filed as required.

Corrective Action Plan

2019-007 - Reporting 1. Corrective action plan: Complete HUD monitoring responses and Authority audits from 2018 through 2021 to determine final federal expenditures amounts for each year. 2. Prepared quarterly SF-425s with correct information. 3. Revise APRs for years 2018-2020. 4. Policy and procedures have been reviewed and updated to insure that accurate reporting for the future award periods have been implemented. 5. All grants have been entered into the accounting software with associated reporting codes. Revenue and Expenditure reports have been developed to insure that financial information can be processed at the end of each reporting period and information transferred to the required reports. Personnel responsible for corrective action: Finance Officer prepares the financial information for the SF-425s and Annual Performance Report (APR). This information is submitted to the Executive Director. The Executive Director approves the SF-425s and returns to the Finance Officer for submission to various contacts relating to each individual award. The Executive Director enters the financial information into the APR and submits it to the funding agency. Estimated corrective action completion date: The December 31, 2020 and 2021 audits should show continue improvements in this area. The goal is to have all reports completed during 2022 after the resolution of the HUD monitoring findings and the December 31, 2021 audit.

About Reporting →
2019-008
Special Tests & Provisions
MATERIAL WEAKNESS
Condition

2019-008 ? Special Test and Provisions ? Investment of IHBG Funds (Material Weakness) Federal program information: Funding agency: U.S. Department of the Housing and Urban Development (HUD) Title: Indian Housing Block Grants CFDA number: 14.867 Grant/contract number 55IH3505460 Award period: January 1, 2019 ? December 31, 2019 Criteria: Per 2 CFR 1000.58, PIH Notice 2019-19, describes the requirements for investing Indian Housing Block Grant funds and establishes the basis upon which the Department will determine if a recipient of IHBG funds has the administrative capacity to draw down IHBG funds for investment purposes as authorized under Section 204(b) of the Native American Housing Assistance and Self-Determination Act (NAHASDA). Condition: In 2018, the Authority over drew $380,636 from the LOCCS system. These excess funds were placed in investment and reserve accounts. The Authority was never given investment authority, which is granted by HUD based on an approved request, to invest IHBG funds. Questioned Cost: None. Cause and Effect: Management of the Authority were not aware of IHBG requirements regarding the investment of IHBG funds. These funds were not used for their intended purpose and should have never been drawn down since there was no written approval granting investment authority to earn interest on IHBG funds. Auditors? Recommendations: The Authority should return all applicable funds and return any interest earned with these funds. Management Response: The current Authority?s management and financial staff concur that the Authority is not authorized to draw down excess funds and reinvest them. The transaction that happened in 2018 was made by previous Authority staff to have available funds during the government shut down. The current Authority?s management recognizes that this is not allowed per HUD regulations and that amounts drawn down from the Authority should be utilized within three days. Corrective actions in conjunction with the HUD monitoring and the audit recommendations have been taken.

Corrective Action Plan

2019-008 - Special Tests and Provisions ? Investment of IHBG Funds Corrective action plan: The following actions have been implemented to ensure this type of problem does not happen: 1. The procedures for drawing down from the Line of Credit Control System (eLOCCS) funds have been prepared. When an eLOCCS draw is requested, the amount requested is prepared by preparing financial reports from the accounting system. The reports show the total expenditures made since the previous eLOCCS draw. Any total expenditures in excess of the total revenues received are requested from the eLOCCS system for payment. All expenditures posted to the accounting system were already paid or are scheduled to be paid within the 3-day timeframe. The payment voucher request is prepared by the Finance Officer. The supporting documentation and the voucher are sent to the Executive Director for approval. 2. The interest on the excess funds drawn in 2018 has already been verified by HUD and this amount was returned. Copies of the bank statements are being provided to HUD for additional review. 3. An analysis is being prepared by the Finance Officer that compares the FY 2018-2022 revenues versus expenditures for this award. The information is being prepared from the Schedule of Expenditures of Federal Awards (SEFA) information or audit workpapers provided by the auditors. Currently, the Authority has this information through 2019. When 2020-2021 expenditure audits are completed, the information will be added to the current expenditures for 2022. This will be compared to the eLOCCS report of drawdowns to show that all excess revenues have been currently expended and a return of federal funds to HUD is not required. Personnel responsible for corrective action: Finance Officer Estimated corrective action completion date: Most of these corrections have already occurred. The final comparison of federal revenues to expenditures will be completed after the December 31, 2021 financial statement audit is completed (plan to have this done prior to June 30 clearing house submission date).

About Special Tests and Provisions →
2019-009
Equipment & Real Property
Condition

2019-009 ? Disposal of Capital Asset (Significant Deficiency) Federal program information: Funding agency: U.S. Department of the Housing and Urban Development (HUD) Title: Indian Housing Block Grants CFDA number: 14.867 Grant/contract number 55IH3505460 Award period: January 1, 2019 ? December 31, 2019 Criteria: An arm?s length transaction refers to a transaction in which buyers and sellers act independently without influence by either party. There is a presumption that transactions reflected in the financial statements have been consummated on arm?s-length basis between independent parties. When the parties to a transaction are related, the entity should ensure that the transaction is at arms-length and document that fact. Condition: The Authority disposed and transferred title of a company vehicle to a related party (board member). The two parties entered into an agreement for the individual to pay $4,200 by making payments beginning in April 2019 through August 2021. It appears that the amount paid for the vehicle was substantially less than fair value estimated by Kelley Blue Book which had a range of approximately $21,000-$26,000. Questioned Cost: None. Cause and Effect: The Authority has entered into an agreement with a related party that does not appear to be at arms-length. The Authority did not use independent third-party verification source to validate an estimate of fair value. Auditors? Recommendations: The Authority has entered into an agreement with a related party that does not appear to be at arms-length. The Authority did not use independent third-party verification source to validate an estimate of fair value. Management Response: Current Authority Management understands that the disposition policy for the Authority must be followed when any assets are disposed of. In the future, these steps will be followed.

Corrective Action Plan

2019-009 - Disposal of Capital Assets Corrective action plan: The following steps are in process to correct property management and inventory issues: 1. The disposition policy (included in the procurement policy) is one of the policies scheduled for review by the management team and Board of Directors. It will be updated and verified to insure adherence to the appropriate Federal regulations according to 2 CFR 200. 2. Included in this policy is a list of allowable methods to dispose of assets. These steps will be followed in the future. 3. All appropriate approvals will be obtained prior to disposition. 4. All purchases of capital assets will be paid in full before item is released and title is transferred. Personnel responsible for corrective action: Accountant and Finance Officer, all invoiced staff/managers, Executive Director, Board of Commissioners. Estimated corrective action completion date: The Authority management team has been making adjustments to this process since coming on board in 2020. Accordingly, by 2022, this corrective action plan should be complete.

About Equipment and Real Property Management →
2019-010
Equipment & Real Property
Condition

2019-010 ? Property and Equipment (Significant Deficiency) Federal program information: Funding agency: U.S. Department of the Housing and Urban Development (HUD) Title: Indian Housing Block Grants CFDA number: 14.867 Grant/contract number 55IH3505460 Award period: January 1, 2019 ? December 31, 2019 Criteria: Property records shall be maintained accurately and provide for a description of the property; serial number or other identification number; acquisition date and cost; source of the property; percentage of federal funds used in the purchase of property; location use and condition of the property; and ultimate disposition data including sales price or the method used to determine current fair market value. A physical inventory shall be taken and the results reconciled with the property records at least once every two years to verify the existence, current use and continued need for the property. Condition: The Authority maintains a capital asset listing; however, a physical inventory was not completed within the last two years. Questioned Cost: None. Cause and Effect: Internal control procedures were not in place to ensure a physical inventory is conducted at least once every two years and that all capital asset purchases have been included on the Authority?s capital asset listing. As a result, the Authority is not in compliance with property and grant equipment grant requirements. Auditors? Recommendations: Complete a physical inventory count every two years. Once completed, reconcile the physical inventory documentation to Authority detailed inventory listing and the general ledger control totals. Management Response: Management agrees that annual inventories of capital assets and inventories need to be completed. We are working on amending the policies, updating the capital asset and inventory list and developing inventory procedures.

Corrective Action Plan

2019-010 - Property and Equipment Corrective action plan: The following steps are in process to correct property management and inventory issues: 1. The current policy relating to these items are part of the procurement policy. Property disposition is a separate policy. These policies are being reviewed and updated to ensure compliance with federal regulations. A determination will also be made if the property management and inventory should be a separate policy. Once these revisions are made, the policy will be submitted to the board for approval. 2. As part of the year end audit procedures, the general ledger is reviewed for any additions to be added to the capital asset list. Any other potential additions, changes, dispositions or obsolete items are verified with the Capital Improvements Manager and the Executive Director for adjustment to the financial records. The procedures for this process including the required documentation will be developed by the Finance staff in conjunction with the Capital Improvements Manager. 3. Potential efficiencies of having a materials inventory will be discussed with staff. If approved, bulk purchasing will be implemented after development of the necessary internal controls and procedures. Physical controls and access/use of materials will

About Equipment and Real Property Management →

FY 2016-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on January 8, 2018. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 8, 2018, which was (2964 days ago).

What is a management decision? →
2016-002
Reporting
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →

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