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We audited Oneida Housing Authority (Authority) to determine whether the Authority calculated program income for NAHASDA-assisted 1937 Act properties in accordance with applicable U.S. Department of Housing and Urban Development (HUD) guidance, regulations, and requirements and to observe uses of revenue from NAHASDA-assisted 1937 Act properties.

The Authority failed to track Block Grant rehabilitation or capital expenses for each property and restrict nonprogram income from its Mutual Help program. As a result, more than $2.2 million in combined low-rent and Mutual Help housing receipts were inappropriately classified as nonprogram income during the period July 1, 2002, through June 30, 2007, and the proceeds from the sale of Mutual Help units were not restricted to eligible uses. This occurred because management in place before 2007 did not ensure that policies and procedures for determining and administering program income were implemented. Further, the Authority's financial auditor identified from $60,000 to $100,000 in disbursements for 2006 board expenses as abusive. Those costs were paid from the Authority's local fund which contained nonprogram income from 1937 Act units.

We recommend that HUD (1) require the Authority to implement policies and procedures to determine program income in accordance with HUD requirements, (2) evaluate the Authority's computation of low rent program income and determine whether the estimated unit labor costs are adequate to document the total cost of rehabilitation or capital costs or reclassify the $990,590 in nonprogram income as Block Grant program income, (3) evaluate the Authority's computation of Mutual Help program income and determine whether the estimated unit labor costs are adequate to document the total cost of rehabilitation or capital costs or reclassify the $1,238,290 in nonprogram income as Block Grant program income, and (4) require the Authority to implement policies and procedures restricting the use of nonprogram income from Mutual Help proceeds of sale to eligible activities.