Brockton Housing Authority
November 17, 2015 · Read the full official report (PDF) ↗
source
“Below is a summary of our findings and recommendations, with links to each page listed.”
Read the plain-English breakdown
This is a state performance audit of the Brockton Housing Authority covering January 1, 2012 through December 31, 2013.
“In accordance with Chapter 11, Section 12, of the Massachusetts General Laws, the Office of the State Auditor has conducted an audit of certain activities of the Brockton Housing Authority for the period January 1, 2012 through December 31, 2013.”
Auditors reviewed selected housing authority operations, including finances, tenant eligibility, procurement, inspections, leases, cost allocation, and required reporting.
“In this performance audit, we reviewed and assessed selected activities of the Authority, such as certain aspects of its financial operations, tenant eligibility, procurement of goods and services, site inspections, contracting and leasing, cost allocation, and compliance with applicable reporting and data-collection requirements.”
These issues matter because they involve public money, housing access, oversight, and whether the authority followed state rules.
“This meant that the Authority did not provide DHCD with necessary information for oversight and transparency.”
For residents and applicants, the most direct issue was that empty apartments took too long to refill, which may have delayed housing for eligible people and reduced rent revenue.
“As a result, the Authority may have lost the opportunity to earn approximately $28,787 in rental income, and eligible applicants in need of state-aided housing may have experienced unnecessary delays in obtaining it.”
The authority was partly compliant in some areas, but auditors found six problems that needed correction.
“The Authority should take the necessary measures to ensure that it reoccupies units within an average of 21 days.”
The audit recommended fixes, and the authority said it had taken or planned steps such as improving approval systems, correcting salary reports, changing laundry controls, and trying to file reports on time.
“The Housing Authority will make every effort to submit its year-end financial statements within the required time frame and ensure that each Board member fully understands what they are voting to approve.”
The audit’s significance is that it pointed to avoidable risks: possible overpayment, weak cash oversight, delayed housing placements, late reports, and records that did not meet DHCD requirements.
“Not filing these reports with DHCD on time could jeopardize the Authority’s operating subsidies for the following quarter.”
Internal controls means practical safeguards, such as checks, records, approvals, and monitoring, that help protect money and make sure rules are followed.
“These controls should safeguard assets such as cash; promote efficiency; encourage compliance with appropriate policies, rules, and regulations; and ensure accuracy of accounting records.”
2 figure(s) pending source verification - not shown
What the Auditor checked
- Partially Did the Authority properly administer its financial operations, including reasonableness of administrative expenses such as executive compensation and benefits, rent collections, subsidy calculations, the collectability of accounts receivable, cash controls, and the administration and oversight of modernization fund expenditures?
- Partially Did the Authority determine tenant eligibility, placement, and monthly rent in accordance with the Department of Housing and Community Development’s (DHCD’s) regulations?
- Complied Did the Authority procure goods and services in accordance with applicable laws and regulations and properly safeguard its assets?
- Complied Were the Authority’s site inspections adequate to ensure that housing units met safety and sanitation requirements?
- Complied Did the Authority procure its contracts and leases in accordance with applicable laws and regulations?
- Complied Is the Authority’s cost-allocation methodology reasonable, do amounts support budgeted items, and does the plan reflect an equitable distribution between state and federal programs?
- Did not comply Did the Authority comply with DHCD’s financial reporting and data-collection requirements?
- Complied Were transactions involving financial and/or management activities between the Authority and related associations, corporations, or other private entities compliant with applicable laws, rules, and regulations?
What the Auditor found
Why it matters: The executive director’s compensation exceeded what DHCD allowed, and the payout was not supported by his contract or documented board approval.
Standard: DHCD Public Housing Notice 2012-02 and the former executive director’s contract. ( DHCD’s Public Housing Notice 2012-02 )
2 recommendations
- Ensure executive-director compensation, including accrued vacation and sick time, stays within contract and DHCD limits.agency: agreed
- Document board decisions about executive-director contracts in meeting minutes.agency: agreed
Agency response & Auditor reply
Agency: "The Authority agrees with this finding."
Why it matters: DHCD lacked accurate information needed for oversight and transparency.
Standard: DHCD Public Housing Notice 2012-03. ( DHCD Public Housing Notice 2012-03 )
2 recommendations
- Submit corrected salary amounts for the five highest-paid employees for fiscal years 2012 and 2013.
- Train appropriate staff and take measures to ensure correct salary information is submitted in the future.
Agency response & Auditor reply
Agency: "There may have been a misunderstanding of the Public Housing Notice 2012-03 but there was no attempt to avoid transparency on this issue."
Why it matters: The Authority could not be certain it received the correct amount of laundry revenue and lacked a current agreement to enforce vendor responsibilities.
Standard: DHCD Accounting Manual and National Association of State Comptrollers Internal Control Questionnaire guidance on cash controls. ( DHCD Accounting Manual; National Association of State Comptrollers Internal Control Questionnaire, “Cash, Petty Cash, Change Funds, and Credit Cards” )
2 recommendations
- Amend non-rental cash receipt policies to include procedures for monitoring laundry receipts with the vendor.
- Maintain a current lease with the laundry-machine vendor.
Agency response & Auditor reply
Agency: "In response to this issue the Brockton Housing Authority contacted our laundry vendor and requested that we set up a three month monitoring protocol to ensure that accurate accounting was being provided for the laundry receipts."
Why it matters: The Authority may have lost rental income and delayed housing for eligible applicants.
Standard: Chapter 1 of DHCD’s Property Maintenance Guide. ( Chapter 1 of DHCD’s Property Maintenance Guide )
1 recommendation
- Take necessary measures to reoccupy units within an average of 21 days.
Agency response & Auditor reply
Agency: "Our records indicate 74 units were over 21 calendar days from notice of vacancy to re-occupancy and 11 units were turned over within the 21 calendar days."
Auditor: "The Authority should continue its efforts to renovate its units within DHCD’s 21-working-day timeline."
Why it matters: Late filings could jeopardize operating subsidies and create revenue or cash shortfalls.
Standard: DHCD Public Housing Notices 2011-11 and 2012-11 and Section 10 of the DHCD Accounting Manual. ( DHCD Public Housing Notices 2011-11 and 2012-11; Section 10 of the DHCD Accounting Manual )
1 recommendation
- Submit quarterly operating statements within the month after quarter-end and year-end operating statements within 45 days after year-end.
Agency response & Auditor reply
Agency: "The Housing Authority will make every effort to submit its year-end financial statements within the required time frame and ensure that each Board member fully understands what they are voting to approve."
Why it matters: The electronic waiting list may not have adequate controls to ensure accurate applicant placement or preserve public records.
Standard: 760 Code of Massachusetts Regulations 5.16(2). ( 760 Code of Massachusetts Regulations 5.16(2) )
1 recommendation
- Use handwritten ledgers or obtain a DHCD waiver allowing electronic waiting lists.agency: disagreed
Agency response & Auditor reply
Agency: "The [Authority] maintains a handwritten applicant ledger."
Auditor: "During the audit, the Authority was unable to provide evidence of a waiver from DHCD for the regulation that requires handwritten ledgers."