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We audited the Chukchansi Indian Housing Authority (Authority) Indian Housing Block Grant program due to a hotline complaint.  The complaint alleged that the Picayune Rancheria of Chukchansi Indians (tribe) had overstated tribal enrollment numbers to the U.S. Department of Housing and Urban Development (HUD), resulting in its tribally designated housing entity, the Chukchansi Indian Housing Authority, receiving more funding than it should have.  Our objective was to determine whether the Authority accurately reported and supported its tribal enrollment numbers as required by HUD.  In addition, we wanted to determine whether the Authority administered its program funds in accordance with HUD rules and requirements.

The allegations in the complaint had merit.  The Authority overstated its tribal enrollment numbers on HUD’s formula response form used for its 2015 and 2016 program funding.  This condition occurred because the Authority did not have controls in place to ensure accurate reporting.  We attempted to verify the accuracy of the tribal enrollment numbers; however, the tribe restricted access to the tribal enrollment files, which created a scope limitation in completing the audit.  In addition, the Authority did not always adequately support the eligibility of program funds spent and did not process program expenses with complete documentation in accordance with HUD’s and its own rules and requirements.  This condition occurred because the Authority did not always follow its own policies and procedures.  As a result, it received $248,222 in excess program funds, awarded more than $1.7 million in program funds that could not be verified, and spent $548 in program funds without proper supporting documentation.

We recommend that the Acting Administrator of HUD’s Southwest Office of Native American Programs recapture the $248,222 in excess program funds from the Authority and require the Authority to ensure the accuracy of and support the tribal enrollment numbers in 2015 and 2016 for more than $1.7 million in unsupported program funds.  In addition, HUD should require  the Authority to (1) establish and implement formal written policies and procedures to document the process for obtaining and verifying tribal enrollment numbers, (2) support the eligibility of $548 in unsupported costs or repay the program using non-Federal funds, and (3) implement controls to ensure that all required documentation for future program expenses is complete.

Recommendation Status Date Issued Summary
2017-LA-1007-001-A Cerrado Agosto 24, 2017 Recapture the $248,222 in excess program funds from the Authority and allocate in the pool for other tribes to use in meeting program objectives.
2017-LA-1007-001-B Cerrado Agosto 24, 2017 Require the Authority to provide source documentation to determine the accuracy of the tribal enrollment numbers reported in 2015 and 2016. Based on those supported numbers, HUD should recapture or offset the unsupported amounts from the awarded $1,746,658 in program funds that resulted from under or overstated tribal enrollment numbers.
2017-LA-1007-001-C Cerrado Agosto 24, 2017 Require the Authority to establish and implement controls and formal written policies and procedures to ensure that accurate tribal enrollment numbers are reported to the Formula Service Center and HUD for future grant years.
2017-LA-1007-002-A Cerrado Agosto 24, 2017 Support the eligibility of the reported $548 in unsupported program costs or repay its program using non-Federal funds.
2017-LA-1007-002-B Cerrado Agosto 24, 2017 Implement controls to ensure that all future check request forms are complete for proper tracking in its accounting records and authorized approver verifies source documentation is attached prior to check issuance for future program expenses as required by its own policies and procedures.