EIN: 936002316
UEI: H8F3KZ3X4LC3
Audit also covers EIN: 930600166 · unlinked EINs have no separate FAC filing
Audited by: Talbot, Korvola & Warwick, LLP
Cognizant agency: 14 [Department of Housing and Urban Development]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 24, 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 September 24, 2026 (16 days from today).
What is a management decision? →Documentation supporting the expenditures included in the Project and Expenditure Report was not retained after the report was submitted.; Cause: The cause appears to be attributable to a lack of consistently applied procedures for retention of data files supporting American Rescue Plan Act (ARPA) reports submitted. The data file used to track expenditures reported was overwritten after the report was submitted. Additionally, rather than using the County’s ARPA/SLFRF shared folder to maintain and track this supporting documentation, the support was emailed between employees to obtain the appropriate review. Due to turnover, employees with access to these documents are no longer with the County and the tracking file supporting expenditures reported could not be located.; Effect or potential effect: A lack of effective internal controls over review of reports may potentially result in reporting inaccurate amounts.; Questioned costs: No known or estimated questioned costs identified.; Context: Out of a population of four quarterly Project and Expenditure Reports, two reports were sampled; one report selected did not include the expenditure detail and could not be located.; Repeat finding: No.; Recommendation: The County should develop and implement policies and procedures to ensure that all ARPA/SLFRF program report support is retained. Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds; Federal agency: U.S. Department of Treasury; Award year: 2025; Criteria: Per the 2025 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, Project and Expenditure Reports are required to be submitted quarterly as specified in the Treasury’s SLFRF Compliance and Reporting Guidance.; Condition: Documentation supporting the expenditures included in the Project and Expenditure Report was not retained after the report was submitted.; Cause: The cause appears to be attributable to a lack of consistently applied procedures for retention of data files supporting American Rescue Plan Act (ARPA) reports submitted. The data file used to track expenditures reported was overwritten after the report was submitted. Additionally, rather than using the County’s ARPA/SLFRF shared folder to maintain and track this supporting documentation, the support was emailed between employees to obtain the appropriate review. Due to turnover, employees with access to these documents are no longer with the County and the tracking file supporting expenditures reported could not be located.; Effect or potential effect: A lack of effective internal controls over review of reports may potentially result in reporting inaccurate amounts.; Questioned costs: No known or estimated questioned costs identified.; Context: Out of a population of four quarterly Project and Expenditure Reports, two reports were sampled; one report selected did not include the expenditure detail and could not be located.; Repeat finding: No.; Recommendation: The County should develop and implement policies and procedures to ensure that all ARPA/SLFRF program report support is retained. Views of responsible officials: The County understands and concurs with the finding.
AL 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding: Documentation supporting the expenditures included in the Project and Expenditure Report was not retained after the report was submitted. Auditor Recommendation: The County should develop and implement policies and procedures to ensure that all ARPA/SLFRF program report support is retained. Corrective Actions Taken or Planned: The County agrees and concurs. In addition to the grants coordinator position a new grant accountant will be starting in the spring of 2026 to improve grant oversight and administration. The board adopted a Grants Policy on 1/20/2026. Point of Contact for corrective actions: Sarah Keane, Deputy CFO sarah_keane@washingtoncountyor.gov
Procurement methods did not always follow Uniform Guidance requirements. Contracts were directly awarded to vendors without full and open competition or obtaining price or rate quotations from an adequate number of qualified sources.; Cause: The cause appears to be attributable to lack of staff training and knowledge regarding federal grant procurement requirements and which contracts support federal awards. Program staff did not appear to be aware that all federal grant contracts are required to comply with a competitive bid process, and instead applied federal funding to contracts that were directly awarded.; Effect or potential effect: Not conducting open competition or solicitation of quotations or bids could result in higher grant program costs by missing the opportunity to select the best available vendor source in the market.; Questioned costs: No known or estimated questioned costs identified.; Context: Out of a population of 100 contracts above the micro purchase threshold of $10,000 and below the simplified acquisition threshold of $250,000, two of thirteen contracts selected for testing did not follow required Uniform Guidance procurement procedures.; Repeat finding: No.; Recommendation: The County should provide training to staff regarding Uniform Guidance rules of procurement and how to identify which contracts support federal award programs.; Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds; Federal agency: U.S. Department of Treasury; Award year: 2025; Criteria: Per the 2025 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement I., Procurement and Suspension and Debarment, recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. Per Uniform Guidance section 2 CFR 200.319(a): All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and section 200.320. Per section 2 CFR 200.320(a)(2)(i): …If simplified acquisition procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources...; Condition: Procurement methods did not always follow Uniform Guidance requirements. Contracts were directly awarded to vendors without full and open competition or obtaining price or rate quotations from an adequate number of qualified sources.; Cause: The cause appears to be attributable to lack of staff training and knowledge regarding federal grant procurement requirements and which contracts support federal awards. Program staff did not appear to be aware that all federal grant contracts are required to comply with a competitive bid process, and instead applied federal funding to contracts that were directly awarded.; Effect or potential effect: Not conducting open competition or solicitation of quotations or bids could result in higher grant program costs by missing the opportunity to select the best available vendor source in the market.; Questioned costs: No known or estimated questioned costs identified.; Context: Out of a population of 100 contracts above the micro purchase threshold of $10,000 and below the simplified acquisition threshold of $250,000, two of thirteen contracts selected for testing did not follow required Uniform Guidance procurement procedures.; Repeat finding: No.; Recommendation: The County should provide training to staff regarding Uniform Guidance rules of procurement and how to identify which contracts support federal award programs.; Views of responsible officials: The County understands and concurs with the finding.
AL 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding: Procurement methods did not always follow Uniform Guidance requirements. Contracts were directly awarded to vendors without full and open competition or obtaining price or rate quotations from an adequate number of qualified sources. Auditor Recommendation: The County should provide training to staff regarding Uniform Guidance rules of procurement and how to identify which contracts support federal award programs. Corrective Actions Taken or Planned: The County agrees and concurs. The County anticipates providing more training to grant program managers and additional reviews during FY26 as the program closes out. Point of Contact for corrective actions: Sarah Keane, Deputy CFO sarah_keane@washingtoncountyor.gov
Evidence was not retained of monitoring subrecipients’ financial and single audit reporting or of any follow up actions as a result of monitoring.; Cause: The cause appears to be attributable to a lack of consistently applied procedures for retention of data files supporting the performance of subrecipient monitoring. If the review was performed, it was retained within the employee’s emails and not through use of an ARPA/SLFRF shared folder. The employee performing the review is no longer with the County and the review documentation could not be located. It is undeterminable if this monitoring was performed.; Effect or potential effect: Without adequate review of the subrecipient’s financial and single audit reporting related to program expenditures incurred, the control environment, compliance with laws, regulations, and program requirements, errors or misappropriation of assets could exist without the County's knowledge.; Questioned costs: No known or estimated questioned costs identified.; Context: Out of a population of 14 subrecipients, six were selected for testing for which no evidence was retained indicating the County’s review of financial and single audit reporting of the subrecipients.; Repeat finding: No.; Recommendation: The County should develop and implement policies and procedures to ensure that all subrecipient monitoring is performed and retained.; Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds; Federal agency: U.S. Department of Treasury; Award year: 2025; Criteria: Per the 2025 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement M, Subrecipient Monitoring, pass-through entities are required to perform monitoring of their subrecipients. This is further described in Uniform Guidance 2 CFR 200.332 which states "A pass-through entity must...(e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The passthrough entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports, (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the passthrough entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the passthrough entity as required by § 200.521. (4) Resolve audit findings specifically related to the subaward...".; Condition: Evidence was not retained of monitoring subrecipients’ financial and single audit reporting or of any follow up actions as a result of monitoring.; Cause: The cause appears to be attributable to a lack of consistently applied procedures for retention of data files supporting the performance of subrecipient monitoring. If the review was performed, it was retained within the employee’s emails and not through use of an ARPA/SLFRF shared folder. The employee performing the review is no longer with the County and the review documentation could not be located. It is undeterminable if this monitoring was performed.; Effect or potential effect: Without adequate review of the subrecipient’s financial and single audit reporting related to program expenditures incurred, the control environment, compliance with laws, regulations, and program requirements, errors or misappropriation of assets could exist without the County's knowledge.; Questioned costs: No known or estimated questioned costs identified.; Context: Out of a population of 14 subrecipients, six were selected for testing for which no evidence was retained indicating the County’s review of financial and single audit reporting of the subrecipients.; Repeat finding: No.; Recommendation: The County should develop and implement policies and procedures to ensure that all subrecipient monitoring is performed and retained.; Views of responsible officials: The County understands and concurs with the finding.
AL 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding: Evidence was not retained of monitoring subrecipients’ financial and single audit reporting or of any follow up actions as a result of monitoring. Auditor Recommendation: The County should develop and implement policies and procedures to ensure that all subrecipient monitoring is performed and retained. Corrective Actions Taken or Planned: The County agrees and concurs. The County anticipates providing more training to grant program managers and additional reviews during FY26 as the program closes out. Point of Contact for corrective actions: Sarah Keane, Deputy CFO sarah_keane@washingtoncountyor.gov
HQS inspections as required by N.4 of the 2025 OMB Compliance Supplement were not performed biennially.; Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections.; Effect or potential effect: Without performing HQS inspections biennially, units could be leased that do not meet standards.; Questioned costs: No known or estimated questioned costs identified.; Context: The required HQS inspection was not performed within 24 months, including the extension period. Out of a population of 2,814 active participants/tenants, 40 units/tenants were selected for testing, and the HQS inspection was not performed within the required inspection period for 10 units/tenants. Repeat finding: Yes.; Recommendation: The County should hire and retain adequate staffing to ensure HQS inspections for all tenants are performed biennially.; Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 14.871, 14.879, 14. EHV Housing Voucher Cluster; Federal agency: U.S. Department of Housing and Urban Development (HUD); Award year: 2025; Criteria: Per the 2025 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.4., NSPIRE/Housing Quality Standards Inspections, requires the County to conduct Housing Quality Standards (HQS) inspections for units leased at least biennially to determine the unit meets the standard.; Condition: HQS inspections as required by N.4 of the 2025 OMB Compliance Supplement were not performed biennially.; Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections.; Effect or potential effect: Without performing HQS inspections biennially, units could be leased that do not meet standards.; Questioned costs: No known or estimated questioned costs identified.; Context: The required HQS inspection was not performed within 24 months, including the extension period. Out of a population of 2,814 active participants/tenants, 40 units/tenants were selected for testing, and the HQS inspection was not performed within the required inspection period for 10 units/tenants. Repeat finding: Yes.; Recommendation: The County should hire and retain adequate staffing to ensure HQS inspections for all tenants are performed biennially.; Views of responsible officials: The County understands and concurs with the finding.
AL 14.871, 14.879, 14. EHV Housing Voucher Cluster Finding: HQS inspections as required by N.4 of the 2025 OMB Compliance Supplement were not performed biennially. Auditor Recommendation: The County should hire and retain adequate staffing to ensure HQS inspections for all tenants are performed biennially. Corrective Actions Taken or Planned: The County agrees and concurs. During FY26, the County hired additional staff to conduct inspections, with a current total of 3.5 FTE. Point of Contact for corrective actions: Sarah Keane, Deputy CFO sarah_keane@washingtoncountyor.gov
2024-008
FAC accepted this audit on June 20, 2025 — management decision was due December 20, 2025.
Internal controls over compliance with requirement L. related to reporting in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to new staff taking over responsibility and lack of awareness for having a consistent review performed prior to submission of this report to HUD. Effect: A lack of effective internal controls over review of monthly reports may potentially result in reporting inaccurate amounts. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 HUD 52681-B reports, four reports were selected for testing, and no review occurred for all four reports by someone other than the preparer. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer. Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster Federal agency: U.S. Department of Housing and Urban Development (HUD) Award year: 2024 Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, the information formerly included in Section 3 of the HUD 52681-B report is required to be submitted monthly in HUD’s most current automated system. Condition: Internal controls over compliance with requirement L. related to reporting in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to new staff taking over responsibility and lack of awareness for having a consistent review performed prior to submission of this report to HUD. Effect: A lack of effective internal controls over review of monthly reports may potentially result in reporting inaccurate amounts. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 HUD 52681-B reports, four reports were selected for testing, and no review occurred for all four reports by someone other than the preparer. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer. Views of responsible officials: The County understands and concurs with the finding.
Auditor recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer. Management response: Agree Target date to complete implementation activities: July 2026 Name of specific point of contact for implementation: Ryan Bansbach, Deputy CFO, Housing, 503.846.8811 Response: The Housing Authority of Washington County (HAWC) is addressing these findings by implementing systems and policies that require secondary review of reports and determinations prior to upward reporting, voucher issuance, or tenant move‐in. HAWC implemented systems in 2025 where the staff preparing and submittng the HUD 52681‐B form will send to the form to the Program Manager or Designee for review and approval stamp before the form is submitted to HUD in the VMS or eVMS system. A checklist has been created and a system updated on routing files after review for eligibility to have a secondary review and final approval prior to issuance of voucher by the program supervisor, program manager or designee. Additional training and internal quality control checks will be implemented to ensure that metric is met. HAWC has also established checklists and procedures to ensure Rent Reasonableness is reviewed and approved prior to tenant move‐in, using a third‐party system to conduct the rent reasonableness determinations. This metric will also be added to the internal quality control procedures to monitor compliance.
Internal controls over compliance with requirement E. related to eligibility in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to the inconsistency of document retention policy and training of personnel. While program staff are required to upload supporting review documents in the Section 8 Program shared folder, some staff only attached documents via email and sent them to a supervisor. When the employment of both staff and supervisor ended at the County, the supporting files went missing. Effect: A lack of effective internal controls over tenant eligibility files may result in errors in eligibility and potential admission and HAP payments to ineligible applicants. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 2,716 active participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for one participant/tenant.Out of a population of 263 new participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for five participants/tenants. Additionally, it was noted that for two of the samples selected, there was an action code error in the HUD 50058 family report form noting them as new admissions when they were existing participants. Out of a population of 152 discontinued participants/tenants, 16 tenants were selected for testing, and the review of eligibility documentation had not been retained for two participants/tenants. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all eligibility documents are reviewed and retained. Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster Federal agency: U.S. Department of Housing and Urban Development (HUD) Award year: 2024 Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement E., Eligibility, condition of admission or continued occupancy is required to obtain necessary information from tenant and (or) other family members and review the necessary information by program supervisor or program manager. Condition: Internal controls over compliance with requirement E. related to eligibility in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to the inconsistency of document retention policy and training of personnel. While program staff are required to upload supporting review documents in the Section 8 Program shared folder, some staff only attached documents via email and sent them to a supervisor. When the employment of both staff and supervisor ended at the County, the supporting files went missing. Effect: A lack of effective internal controls over tenant eligibility files may result in errors in eligibility and potential admission and HAP payments to ineligible applicants. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 2,716 active participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for one participant/tenant.Out of a population of 263 new participants/tenants, 25 tenants were selected for testing, and the review of eligibility documentation had not been retained for five participants/tenants. Additionally, it was noted that for two of the samples selected, there was an action code error in the HUD 50058 family report form noting them as new admissions when they were existing participants. Out of a population of 152 discontinued participants/tenants, 16 tenants were selected for testing, and the review of eligibility documentation had not been retained for two participants/tenants. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all eligibility documents are reviewed and retained. Views of responsible officials: The County understands and concurs with the finding.
Auditor recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer. Management response: Agree Target date to complete implementation activities: July 2026 Name of specific point of contact for implementation: Ryan Bansbach, Deputy CFO, Housing, 503.846.8811 Response: The Housing Authority of Washington County (HAWC) is addressing these findings by implementing systems and policies that require secondary review of reports and determinations prior to upward reporting, voucher issuance, or tenant move‐in. HAWC implemented systems in 2025 where the staff preparing and submittng the HUD 52681‐B form will send to the form to the Program Manager or Designee for review and approval stamp before the form is submitted to HUD in the VMS or eVMS system. A checklist has been created and a system updated on routing files after review for eligibility to have a secondary review and final approval prior to issuance of voucher by the program supervisor, program manager or designee. Additional training and internal quality control checks will be implemented to ensure that metric is met. HAWC has also established checklists and procedures to ensure Rent Reasonableness is reviewed and approved prior to tenant move‐in, using a third‐party system to conduct the rent reasonableness determinations. This metric will also be added to the internal quality control procedures to monitor compliance.
Internal controls over compliance with requirement N.2 related to reasonable rent in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to supporting documentation not retained in internal County folder but rather only exchanged between program staff and supervisor. When employment of both program staff and program supervisor ended, the supporting documentation went missing. Additionally, the County made efforts to convert paper documents to digital, but not all paper documents were converted to digital format and files were not located. Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance payments. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for two units/tenants. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained. Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster Federal agency: U.S. Department of Housing and Urban Development (HUD) Award year: 2024 Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.2., Reasonable Rent, requires the County to conduct a reasonable rent analysis when tenant is admitted to a new unit. Condition: Internal controls over compliance with requirement N.2 related to reasonable rent in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to supporting documentation not retained in internal County folder but rather only exchanged between program staff and supervisor. When employment of both program staff and program supervisor ended, the supporting documentation went missing. Additionally, the County made efforts to convert paper documents to digital, but not all paper documents were converted to digital format and files were not located. Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance payments. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for two units/tenants. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained. Views of responsible officials: The County understands and concurs with the finding.
Auditor recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer. Management response: Agree Target date to complete implementation activities: July 2026 Name of specific point of contact for implementation: Ryan Bansbach, Deputy CFO, Housing, 503.846.8811 Reponse: The Housing Authority of Washington County (HAWC) is addressing these findings by implementing systems and policies that require secondary review of reports and determinations prior to upward reporting, voucher issuance, or tenant move-in. HAWC implemented systems in 2025 where the staff preparing and submitting the HUD 52681-B form will send to the form to the Program Manager or Designee for review and approval stamp before the form is submitted to HUD in the VMS or eVMS system. A checklist has been created and a system updated on routing files after review for eligibility to have a secondary review and final approval prior to issuance of voucher by the program supervisor, program manager, or designee. Additional training and internal quality control checks will be implemented to ensure that metric is met. HAWC has also established checklists and procedures to ensure Rent Reasonableness is reviewed and approved prior to tenant move-in, using a third-party system to conduct the rent reasonableness determinations. This metric will also be added to the internal quality control procedures to monitor compliance.
Internal controls over compliance with requirement N.4 related to NSPIRE/Housing Quality Standards (HQS) in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections combined with inconsistent document archiving method followed by County staff. Effect: A lack of effective internal controls over HQS inspections may result in units leased that do not meet standards. Questioned costs: No known or estimated questioned costs identified. Context: It was noted that the required HQS inspection had not been performed within 24 months, including the extension period. Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and it was noted that the HQS inspection had not been performed within the required inspection period for one unit/tenant. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all HQS inspections are reviewed and retained. Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 14.871, 14.879, 14.EHV Housing Voucher Cluster Federal agency: U.S. Department of Housing and Urban Development (HUD) Award year: 2024 Criteria: Per the 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.4., NSPIRE/Housing Quality Standards Inspections, requires the County to conduct Housing Quality Standards (HQS) inspections for units leased at least biennially to determine the unit meets the standard. Per the Federal Register announcement in May 2023, HUD extended the compliance date for HCV and PBV programs until October 1, 2024. Condition: Internal controls over compliance with requirement N.4 related to NSPIRE/Housing Quality Standards (HQS) in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to a shortage of inspectors performing HQS inspections combined with inconsistent document archiving method followed by County staff. Effect: A lack of effective internal controls over HQS inspections may result in units leased that do not meet standards. Questioned costs: No known or estimated questioned costs identified. Context: It was noted that the required HQS inspection had not been performed within 24 months, including the extension period. Out of a population of 2,716 active participants/tenants, 25 units/tenants were selected for testing, and it was noted that the HQS inspection had not been performed within the required inspection period for one unit/tenant. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all HQS inspections are reviewed and retained. Views of responsible officials: The County understands and concurs with the finding.
Auditor recommendation: The County should develop and implement policies and procedures to ensure that all HQS inspections are reviewed and retained. Management response: Agree Target date to complete implementation activities: July 2026 Name of specific point of contact for implementation: Ryan Bansach, Deputy CFO, Housing, 503.846.8811 Response: During the audit period, the Housing Authority of Washington County (HAWC) was actively expanding its inspection team, increasing from two to five inspectors. This significant growth, coupled with an increase in the number of units and the ongoing recovery from COVID-19-related operational challenges, contributed to this isolated instance. HAWC has implemented robust reporting mechanisms to monitor inspection schedules and proactively identify any units approaching or exceeding the 24-month inspection window. We are confident that these enhanced procedures and our expanded inspection team will ensure timely NSPIRE/HQS inspections for all HCV and PBV program units moving forward.
Internal controls over compliance with requirement N.1 related to reasonable rental rates in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to lack of staffing and inadequate training for new staff. Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 313 rental units/tenants, 60 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for 3 units/tenants. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained. Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 14.267 Continuum of Care Program Federal agency: U.S. Department of Housing and Urban Development (HUD) Award year: 2024 Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement N.1., Reasonable Rental Rates, requires the County to conduct a reasonable rent analysis. Per 24 CFR 578.49(b)(1) and 24 CFR 578.51(g), when grant funds are used to pay for all or part of the rent for a structure, the rent must be reasonable in relation to rents charged for comparable space in the area. Condition: Internal controls over compliance with requirement N.1 related to reasonable rental rates in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to lack of staffing and inadequate training for new staff. Effect: A lack of effective internal controls over tenant reasonable rent calculations may result in overpayments in housing assistance. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 313 rental units/tenants, 60 units/tenants were selected for testing, and the reasonable rent analysis documentation was not retained for 3 units/tenants. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that all reasonable rent documents are reviewed and retained. Views of responsible officials: The County understands and concurs with the finding.
Auditor recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer. Management response: Agree Target date to complete implementation activities: July 2026 Name of specific point of contact for implementation: Ryan Bansbach, Deputy CFO, Housing, 503.846.8811 Response: The Housing Authority of Washington County (HAWC) is addressing these findings by implementing systems and policies that require secondary review of reports and determinations prior to upward reporting, voucher issuance, or tenant move-in. HAWC implemented systems in 2025 where the staff preparing and submitting the HUD 52681-B form will send to the form to the Program Manager or Designee for review and approval stamp before the form is submitted to HUD in the VMS or eVMS system. A checklist has been created and a system updated on routing files after review for eligibility to have a secondary review and final approval prior to issuance of voucher by the program supervisor, program manager, or designee. Additional training and internal quality control checks will be implemented to ensure that metric is met. HAWC has also established checklists and procedures to ensure Rent Reasonableness is reviewed and approved prior to tenant move-in, using a third-party system to conduct the rent reasonableness determinations. This metric will also be added to the internal quality control procedures to monitor compliance.
Internal controls over compliance with requirement G.1. related to a match of no less than 25% in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to lack of staffing and inadequate training for new staff. Effect: A lack of effective internal controls over the review of payroll and administrative expenditure matching was occurring and may result in unallowable costs being used to match. Questioned costs: No known or estimated questioned costs identified. Context: The match of no less than 25% was appropriately calculated for the fiscal year; however, evidence of a review of the calculations was not retained. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that payroll and administrative expenditure matching is reviewed to ensure the 25% matching requirement is met and costs used to match are allowable. Views of responsible officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal program: AL 14.267 Continuum of Care Program Federal agency: U.S. Department of Housing and Urban Development (HUD) Award year: 2024 Criteria: The 2024 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement G.1., Matching, requires a match of no less than 25%. Condition: Internal controls over compliance with requirement G.1. related to a match of no less than 25% in the 2024 OMB Compliance Supplement were not implemented and operating as designed. Cause: The cause appears to be attributable to lack of staffing and inadequate training for new staff. Effect: A lack of effective internal controls over the review of payroll and administrative expenditure matching was occurring and may result in unallowable costs being used to match. Questioned costs: No known or estimated questioned costs identified. Context: The match of no less than 25% was appropriately calculated for the fiscal year; however, evidence of a review of the calculations was not retained. Repeat finding: No. Recommendation: The County should develop and implement policies and procedures to ensure that payroll and administrative expenditure matching is reviewed to ensure the 25% matching requirement is met and costs used to match are allowable. Views of responsible officials: The County understands and concurs with the finding.
Auditor recommendation: The County should develop and implement policies and procedures to ensure that payroll and administrative expenditure matching is reviewed to ensure the 25% matching requirement is met and costs used to match are allowable. Management response: Agree Target date to complete implementation activities: July 2026 Name of specific point of contact for implementation: Ryan Bansbach, Deputy CFO, Housing, 503.846.8811 Response: The Homeless Division, that administers the programmatic aspect of the Continuum of Care, reviewed budget allocations to subrecipients including the Housing Authority. Although match was reviewed and included in the approved County budget, the Homeless Division is developing and implementing policies and procedures to ensure documentation of match review is retained. In future fiscal years, Washington County has committed the match to subrecipients to ensure the match is met and eligible in alignment with HUD expenses.
FAC accepted this audit on May 24, 2024 — management decision was due November 24, 2024.
FAC accepted this audit on April 30, 2023 — management decision was due October 30, 2023.
FAC accepted this audit on March 4, 2022 — management decision was due September 4, 2022.
Internal controls over compliance and compliance with requirement L. related to reporting in the 2021 OMB Compliance Supplement was not implemented and operating as designed. Cause: The cause appears to be attributable to a change in HUD reporting combined with new project staff needing training and a needed revision in County processes for this reporting. Effect: A lack of effective internal controls over review and filing of annual and quarterly reports resulted in one omitted annual filing and other quarterly reports not evidencing review. Questioned Costs: No known or estimated questioned costs identified. Context: The Section 3 reporting (formerly reported on the HUD 60002 report) has not been prepared, and therefore, not submitted timely, and the quarterly `Cash on Hand? reports were not reviewed before filing on time. Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer and that all reports are filed in a timely manner. View of Responsible Officials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal Program: AL 14.218 CDBG - Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development Award Year: 2020-2021 Criteria: Per the 2021 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, the information formerly included in Section 3 of the HUD annual 60002 report is required to be submitted annually in HUD?s most current automated system. TKW noted that this Section 3 information was not submitted in any report to HUD. Additionally, the Cash on Hand quarterly reports (fka SF-425 reports) were not reviewed before submission. Condition: Internal controls over compliance and compliance with requirement L. related to reporting in the 2021 OMB Compliance Supplement was not implemented and operating as designed. Cause: The cause appears to be attributable to a change in HUD reporting combined with new project staff needing training and a needed revision in County processes for this reporting. Effect: A lack of effective internal controls over review and filing of annual and quarterly reports resulted in one omitted annual filing and other quarterly reports not evidencing review. Questioned Costs: No known or estimated questioned costs identified. Context: The Section 3 reporting (formerly reported on the HUD 60002 report) has not been prepared, and therefore, not submitted timely, and the quarterly `Cash on Hand? reports were not reviewed before filing on time. Recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer and that all reports are filed in a timely manner. View of Responsible Officials: The County understands and concurs with the finding.
Finding: Per the 2021 Office of Management and Budget (OMB) Compliance Supplement, part 4, requirement L., Reporting, the information formerly included in Section 3 of the HUD annual 60002 report is required to be submitted annually in HUD?s most current automated system. TKW noted that this Section 3 information was not submitted in any report to HUD. Additionally, the Cash on Hand quarterly reports (fka SF-425 reports) were not reviewed before submission. Internal controls over compliance and compliance with requirement L. related to reporting in the 2021 OMB Compliance Supplement was not implemented and operating as designed. Corrective Actions Taken or Planned: The procedure for completing the cash on hand quarterly reports has been updated to require Program Manager review and approval prior to submission. Review and approval will be annotated on the documents used to prepare the report each quarter. The Office of Community Development will utilize the new HUD guidance to create policies, procedures, contractual language, reporting forms and set deadlines in order to address the new Section 3 guidance and ensure the reporting function is embedded in office procedures. The above work is expected to be fully completed by May 31, 2022. For questions, please contact Jennie Proctor, Program Manager, at 503-846-8814.
FAC accepted this audit on March 31, 2021 — management decision was due October 1, 2021.
Internal control over compliance requirement M. related to subrecipient monitoring was not evidenced.Cause: The cause appears to be attributable to lack of training and awareness of appropriate review procedures.Effect: A lack of effective internal controls over compliance for subrecipient monitoring may result in administrative errors and improper/missed HOME rental projects not being subjected to monitoring each year.Questioned Costs: There were no questioned costs.Context: We were not able to substantiate evidence of a review over the master HOME project monitoring spreadsheet by someone other than the preparer.Recommendation: The County should develop and implement policies and procedures to ensure that evidence and documentation of a review of the master monitoring trackingspreadsheet is occurring.View of ResponsibleOfficials: The County understands and concurs with the finding.
Show full finding ▾Hide full finding ▴Federal Program: CFDA 14.239 HOME Investment Partnerships ProgramFederal Agency: U.S. Department of Housing and Urban DevelopmentAward Year: 2019-2020Criteria: Per CRF 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues,regulations, and the terms and conditions of the Federal award.Condition: Internal control over compliance requirement M. related to subrecipient monitoring was not evidenced.Cause: The cause appears to be attributable to lack of training and awareness of appropriate review procedures.Effect: A lack of effective internal controls over compliance for subrecipient monitoring may result in administrative errors and improper/missed HOME rental projects not being subjected to monitoring each year.Questioned Costs: There were no questioned costs.Context: We were not able to substantiate evidence of a review over the master HOME project monitoring spreadsheet by someone other than the preparer.Recommendation: The County should develop and implement policies and procedures to ensure that evidence and documentation of a review of the master monitoring trackingspreadsheet is occurring.View of ResponsibleOfficials: The County understands and concurs with the finding.
Finding:Per CRF 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Internal control over compliance requirement M related to subrecipient monitoring was not evidenced.We were not able to substantiate evidence of a review over the master HOME project monitoring spreadsheet by someone other than the preparer.Corrective Actions Taken or Planned:The ability to review, monitor and comply with Federal statutes, regulations is essential to both the conditions of the Federal award and the commitments made by this office. We are taking immediate action to address the issue:- Annually, the Housing and Community Development (HCD) Specialist will draft the master monitoring spreadsheet with the activities that will be reviewed for the coming fiscal year.- The master monitoring schedule will then be reviewed by the Program Manager (PM) and their review will be noted via electronic signature.- Taking these steps is a priority for the Office of Community Development and the office commits to implementing all these measures in the next 90 days to align with the beginning of the next fiscal year.The Office of Community Development respectfully requests that the above plan of action be considered.
FAC accepted this audit on February 9, 2020 — management decision was due August 9, 2020.
CFDA 14.155 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223f/207) U.S. Department of Housing and Urban Development 2018-2019 2 CFR part 200, appendix XI, and per HUD Handbook 2000.04, Chapter 3: I. Cash Disbursements and H. Cash Receipts requires the County and Authority to have a system of internal controls over financial reporting to ensure support, evidence of review, and proper recognition of expense and revenue items. Internal controls over compliance requirements A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, and J. Program Income of the 2019 Office of Management and Budget Compliance Supplement were found not to be implemented as designed. Procedures to retain appropriate documentation, maintain evidence of review, make timely deposits, monitor collectability of accounts receivable, and properly cutoff accounts payable were not properly followed by property management personnel. Questioned Costs: There was $6,814 of unsupported administrative and repair and maintenance expense items out of a total tested amount of $25,258. There was also rental income net of vacancy loss unsupported amounts of $(1,071) out of a total tested net rental revenue amount of $10,067. z During our testing, the property management company was unable to provide support for ten administrative and repair and maintenance expense items out of a sample of 35 items and five rental revenue items out of a sample of 38 items. In addition, $1,075 of accounts payable was not recorded at year end, and $6,694 of accounts receivable appears to be uncollectible and an allowance for doubtful accounts was not recorded. Financial reporting may include improperly recognized expenses, revenue, accounts payable and accounts receivable. The cause appears to be attributable to lack of training and knowledge by property management personnel. Relevant property management company personnel should be properly trained and adhere to established financial reporting procedures. Management of the County and Authority understands and concurs with the finding and recommendation.
Show full finding ▾Hide full finding ▴Finding 2019-001Finding 2019-001 Federal Program: Federal Agency: Award Year: Criteria: Condition: CFDA 14.155 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223f/207) U.S. Department of Housing and Urban Development 2018-2019 2 CFR part 200, appendix XI, and per HUD Handbook 2000.04, Chapter 3: I. Cash Disbursements and H. Cash Receipts requires the County and Authority to have a system of internal controls over financial reporting to ensure support, evidence of review, and proper recognition of expense and revenue items. Internal controls over compliance requirements A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, and J. Program Income of the 2019 Office of Management and Budget Compliance Supplement were found not to be implemented as designed. Procedures to retain appropriate documentation, maintain evidence of review, make timely deposits, monitor collectability of accounts receivable, and properly cutoff accounts payable were not properly followed by property management personnel. Questioned Costs: There was $6,814 of unsupported administrative and repair and maintenance expense items out of a total tested amount of $25,258. There was also rental income net of vacancy loss unsupported amounts of $(1,071) out of a total tested net rental revenue amount of $10,067. z During our testing, the property management company was unable to provide support for ten administrative and repair and maintenance expense items out of a sample of 35 items and five rental revenue items out of a sample of 38 items. In addition, $1,075 of accounts payable was not recorded at year end, and $6,694 of accounts receivable appears to be uncollectible and an allowance for doubtful accounts was not recorded. Financial reporting may include improperly recognized expenses, revenue, accounts payable and accounts receivable. The cause appears to be attributable to lack of training and knowledge by property management personnel. Relevant property management company personnel should be properly trained and adhere to established financial reporting procedures. Management of the County and Authority understands and concurs with the finding and recommendation.
Finding 2019-001
FAC accepted this audit on January 15, 2019 — management decision was due July 15, 2019.
FAC accepted this audit on January 9, 2018 — management decision was due July 9, 2018.
FAC accepted this audit on January 5, 2017 — management decision was due July 5, 2017.
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